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Seattle Audubon Society v. Evans

United States District Court for the Western District of Washington
771 F. Supp. 1081 (1991)


Facts

In early 1989, the Seattle Audubon Society (SAS) (plaintiff) sued the United States Forest Service (USFS) (defendant), challenging the USFS’s adoption of standards and guidelines for managing northern-spotted-owl (owl) habitat in national forests. In April 1989, the Fish and Wildlife Service (FWS) announced that the owl would be listed as a threatened species under the Endangered Species Act (ESA), 16 U.S.C. §§ 1531 et seq. The district court issued a stay to allow the FWS and the USFS to consult. However, after the stay, the USFS did not adopt promised temporary guidelines to protect the owl. During this time, Congress enacted section 318 of the Department of the Interior and Related Agencies Appropriations Act, which directed the USFS to prepare a new plan for the owl. The USFS failed to prepare the plan. In June 1990, the FWS listed the owl as threatened under the ESA. In December 1990, the district court found that the FWS had violated the ESA by failing to designate the owl’s critical habitat. The district court also enjoined the USFS from proceeding with timber sales, finding that the USFS had violated the National Forest Management Act (NFMA), 16 U.S.C. §§ 1600 et seq., by failing to create standards or guidelines for owl viability. In March 1991, the district court entered summary judgment against the USFS, finding that the USFS’s proposal to log owl habitat in national forests violated the NFMA. The district court also found that the USFS’s duties under the NFMA and ESA were concurrent. SAS moved for a permanent injunction to prohibit the sale of logging rights in owl habitat until the USFS complied with the NFMA by adopting standards and guidelines to ensure the owl’s viability.

Rule of Law

Issue

Holding and Reasoning (Dwyer, J.)

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