Newton County Wildlife Association v. United States Forest Service
United States Court of Appeals for the Eighth Circuit
113 F.3d 110 (1997)
Section 1271(d)(1) of the Wild and Scenic Rivers Act (Act), 16 U.S.C. § 1271(d)(1), required each agency administering river segments designated as components of the federal wild-and-scenic-river system to prepare a comprehensive management plan (plan) protecting river values. Section 1274(b) of the Act, 16 U.S.C. § 1274(b), allowed the administering agency to determine the boundaries of each component. Section 1281(a) of the Act, 16 U.S.C. § 1281(a), linked agency planning and administration to each component. In 1992, Congress designated six river segments within the Ozark National Forest (forest) as components under the Act. The Act required the United States Forest Service (USFS) (defendant) to complete a plan for each segment within the forest by September 30, 1995. Although the USFS did not meet the deadline, the USFS approved four timber sales within the forest prior to the deadline. The Newton County Wildlife Association, the Sierra Club, and various individuals (plaintiffs) sued the USFS to enjoin the timber sales. The plaintiffs claimed that the sales violated the Act because the sales took place before the USFS’s completion of its plans. The district court found that the plans encompassed areas that could affect designated river segments, even if the areas were located outside of the segments. The district court declined to issue an injunction, and the plaintiffs appealed.
Rule of Law
Holding and Reasoning (Loken, J.)
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