Sierra Club v. Department of the Interior

In 1968, the United States Congress passed the Redwood National Park Act (redwood act) to preserve coastal redwood forests. The redwood act authorized the secretary of the United States Department of the Interior (defendant) to take private land in exchange for just compensation near Redwood National Park (the park) if taking the land would prevent damage to park resources. The secretary had the power to modify the boundaries of the park to protect streams and timber. The secretary also had the power and to enter into contracts and cooperative agreements with nearby landowners to ensure that activities such as logging would not adversely affect park resources. Further, the secretary had a general fiduciary duty to conserve natural resources in national parks. Starting in 1969, the secretary conducted studies of the damage and threats of damage to the park caused by logging on land near the park. The studies resulted in recommendations of actions for the secretary to take to minimize such damage. The recommendations included the acquisition of land to enlarge park boundaries, the acquisition of management zones and easements, the acquisition of land along streams, and the imposition of a logging moratorium along streams. The secretary did not implement any of the recommendations except entering into purported cooperative agreements with nearby timber companies. The secretary also directed further studies to be conducted. The cooperative agreements with the timber companies were not legally binding, enforceable contracts because the agreements had not been properly executed. Further, the language of the agreements was practically meaningless, and even if the agreements were enforceable, they were inadequate to prevent or minimize the ongoing damage to park resources caused by logging. The only positive result from the agreements was a mere voluntary abstention from logging within 800 feet of the park for several years. The Sierra Club (plaintiff) sued the secretary, alleging that the secretary’s actions in failing to implement the recommendations to protect the park were arbitrary, capricious, and an abuse of discretion, which violated the redwood act and the secretary’s general fiduciary duty to protect the park.