On December 19, 2025, the federal district court granted plaintiff North Dakota and federal defendants’ request to dismiss North Dakota’s action challenging a Resource Management Plan (RMP) amended during the Biden administration to restrict future coal development on federal lands in the state. The parties had notified the court that President Trump signed a resolution on December 11, 2025 that disapproved and nullified the amended RMP under the Congressional Review Act. The parties therefore requested that the case be dismissed as moot.

Challenge to the amended Resource Management Plan for federal lands in North Dakota that was approved in the final days of the Biden administration and that restricted development of new coal resources.

North Dakota v. U.S. Department of the Interior

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North Dakota’s Challenge to Biden-Era Restrictions on Federal Coal Development Dismissed as Moot After Congressional Review Act Nullification

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