Mayo v. Reynolds
United States Court of Appeals for the District of Columbia Circuit
875 F.3d 11 (2017)
- Written by Colette Routel, JD
Facts
In 2007, the National Park Service authorized annual elk hunts as a means of reducing the herd within Grand Teton National Park. It made this decision after conducting a review of the environmental impacts likely to occur if elk hunts took place over the following 15 years. Those impacts were summarized in an environmental-impact statement (EIS) pursuant to the National Environmental Policy Act of 1969 (NEPA). In 2015, when the National Park Service authorized an annual elk hunt in accordance with the 2007 EIS, wildlife photographers Timothy Mayo and Kent Nelson (collectively, the photographers) (plaintiffs) sued Michael Reynolds (defendant), the head of the National Park Service, challenging the agency’s decision to authorize the elk hunt within Grand Teton National Park. The photographers argued that before authorizing an elk hunt in 2015—eight years after the original EIS was completed—the National Park Service was required to complete another EIS or a supplemental EIS to (1) determine whether such a hunt was necessary for the proper management of the elk and (2) assess its environmental impacts. The district court ruled in favor of Reynolds, and the photographers appealed.
Rule of Law
Issue
Holding and Reasoning (Edwards, J.)
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