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SAFARI and the NRA v. United States (ZINKE) [Department of Interior]
United States Court of Appeals for the District of Columbia Circuit
878 F.3d 316 (2017)
The United States was a signatory of the Convention on International Trade in Endangered Species of Wild Fauna and Flora, a treaty that lists endangered species and regulates their trade. Congress passed the Endangered Species Act (ESA), which banned the importation of most threatened and endangered species. The ESA empowered the Department of the Interior (defendant) to make rules to enhance the preservation of endangered species. The Department of the Interior released findings that the Zimbabwean elephant population may have declined and issued a rule that Zimbabwean elephant trophies could not be imported into the United States. The Safari Club and the National Rifle Association (NRA) (plaintiffs) sued in federal district court, claiming that the rule was arbitrary and capricious because the Department of the Interior had not gone through the notice-and-comment period. The Department of the Interior claimed that the rule was actually an adjudication, and the district court agreed. The Safari Club and the NRA appealed the case to the District of Columbia Circuit.
Rule of Law
Holding and Reasoning (Edwards, J.)
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