Sierra Club v. United States Forest Service

In 1920, Congress established the Norbeck Wildlife Preserve (preserve) under the Norbeck Organic Act (Norbeck act). The preserve was part of the Black Hills National Forest. The Norbeck act governed only the preserve and designated the preserve for the protection of game animals and birds. The United States Forest Service (service) (defendant) was responsible for developing and administering management plans for the preserve. In 1927, the service developed a master plan for the preserve, which included the regulation of timber harvests. The master plan stated that the primary purpose of the management of the preserve was wildlife management and that timber cutting must not materially interfere with game animals. Later, Congress passed the National Forest Management Act of 1976 (forest-management act). The forest-management act applied to all land within the National Forest System and mandated the optimization of overall plant and animal diversity. In 1983, the service enacted a comprehensive Black Hills National Forest Land and Resource Management Plan (1983 plan) pursuant to the forest-management act. The 1983 plan covered timber harvesting and sales. Further, the service interpreted the forest-management act to have extended forest-management decisions regarding the preserve beyond the specific parameters of the Norbeck act. Consequently, the 1983 plan emphasized the optimization of overall habitat capability for all plant and animal life rather than specifically game animals and birds. Later, the service developed a timber-harvest plan pursuant to the 1983 plan. The service approved two commercial timber sales under the timber-harvest plan. These sales would have resulted in the removal of timber from thousands of acres of the preserve and over 30 miles of road construction. The service recognized that the timber sales would have resulted in significant disturbance to game and bird species. Despite the deleterious effect that the timber sales would have had on sensitive game and bird species, the service justified the timber-harvest plan as favorable to the overall plant and animal diversity in the preserve. The service had interpreted the more-specific mandates of the Norbeck act to be supplemental or subordinate to the more-general mandates of the forest-management act with respect to preserve management. The Sierra Club (plaintiff) sued the service, claiming that the approval of the timber sales violated the Norbeck act.