Sierra Club v. Martin
United States Court of Appeals for the Eleventh Circuit
168 F.3d 1 (1999)
The United States Forest Service (USFS) (defendant) proposed to sell timber rights for timber projects located within the Chattahoochee and Oconee National Forests (forests). The timber projects involved road construction and water discharges that would threaten wildlife habitat. The Sierra Club (Sierra) (plaintiff) filed suit against the USFS in district court, claiming that the USFS had not collected population data for proposed, endangered, threatened, or sensitive (PETS) plant and animal species, as required by USFS regulations and a forest plan. The district court granted summary judgment to the USFS. Sierra appealed, arguing that the USFS had violated the National Forest Management Act (NFMA), 16 U.S.C. §§ 1600 et seq., and the forest plan by failing to gather population data on PETS species prior to making a decision affecting the forests. Sierra also claimed that the timber sales violated NFMA regulations, 36 C.F.R. §§ 219.26 and 219.19, because the USFS had failed to collect population data for either management-indicator species (MIS) or all affected species. Section 219.26 required the USFS to use population data to assess the forest plan’s effects on species diversity, while § 219.19 required the USFS to monitor MIS populations. The USFS argued that habitat information other than population data was adequate to meet the forest plan’s requirements, that USFS regulations did not require the USFS to keep data on PETS species, and that the timber projects would not significantly impact PETS species’ diversity or viability. The USFS also argued that, when read together, §§ 219.26 and 219.19 required the USFS to collect data only for MIS species. The USFS interpreted § 219.26 to mean that the USFS was not required to collect data for MIS species.
Rule of Law
Holding and Reasoning (Barkett, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 724,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.