Western Energy Alliance v. Haaland

The court found that the lack of lease sales in 2021 was not arbitrary or capricious, as the agency was conducting a review of lease practices following Executive Order 14008, which stated that the Secretary of the Interior shall pause new oil and natural gas leases on public lands and offshore waters, and addressing legal deficiencies in environmental analyses identified in prior litigation. However, the court found that the DOI failed to provide a sufficient explanation for the failure to hold lease sales in the latter half of 2022. The court found that the record provided no explanation for the decision to forgo lease sales, and thus the failure to hold a lease sale in late 2022 was arbitrary and capricious. The court further held that the industry petitioners lacked standing because the petitioners did not allege that their members would have bid or participated in any 2022 lease sales, and thus did not meet the requirement of an "actual or imminent" injury in fact.