Wyoming v. U.S. Department of Agriculture
United States Court of Appeals for the Tenth Circuit
661 F. 3d 1209 (2011)
In 2001, the United States Forest Service (USFS) (defendant) issued the Roadless Area Conservation Rule (rule). The rule was promulgated under the Organic Administration Act of 1897 (Organic Act), 16 U.S.C. §§ 473-482, 551, which gave the USFS broad authority to regulate the occupancy and use of national forests and to protect the forests from destruction. The rule prohibited road construction in inventoried roadless areas (IRAs) located within national forests. The rule also prohibited the cutting, sale, and removal of timber from IRAs, with limited exceptions. The State of Wyoming (state) (plaintiff) challenged the USFS’s rule in district court, claiming that the rule violated the Wilderness Act of 1964 (Wilderness Act), 16 U.S.C. §§ 1131-36, by creating a de facto wilderness designation in violation of the Wilderness Act’s designation process for wilderness areas. The district court agreed with the state, finding that wilderness areas governed by the Wilderness Act were essentially the same as IRAs governed by the rule, and that land uses in IRAs were more restricted than land uses in wilderness areas. The district court entered a permanent injunction against the rule. The USFS appealed, arguing that IRAs were not de facto wilderness areas and that the rule was a valid exercise of its authority.
Rule of Law
Holding and Reasoning (Holmes, 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 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read 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. Read more about Quimbee.
Here's why 176,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 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.