WildEarth Guardians v. U.S. Dept. of Agric. Animal and Plant Health Inspection Serv. Wildlife Services

Authors

• Luke A. Zagar, Alexander Blewett III School of Law, University of MontanaFollow

Case Summary Citation

WildEarth Guardians v. U.S. Dept. of Agric. Animal and Plant Health Inspection Serv. Wildlife Services, 135 F.4th 717 (9th Cir. 2025).

Abstract

WildEarth Guardians v. U.S. Dept. of Agric. Animal and Plant Health Inspection Serv. Wildlife Services considers whether Predator Damage Management (“PDM”) programs in Wilderness Areas violate the Wilderness Act and whether the United States Department of Agriculture’s Animal and Plant Health Inspection Service, Wildlife Services (“Wildlife Services”) violated the National Environmental Policy Act (“NEPA”) in issuing its Final Environmental Assessment (“EA”) and Finding of No Significant Impact (“FONSI”). The Court of Appeals for the Ninth Circuit affirmed its prior holding in Forest Guardians v. Naimal & Plant Health Inspection Serv., finding that “the Wilderness Act does not prohibit Wildlife Service from conducting [PDM] operations in Wilderness Areas.” On the NEPA claim, the Court determined that Wildlife Services’ issuance of the EA and the FONSI violated NEPA by failing to satisfy the “hard look” requirement. The Court agreed with the district court’s grant of summary judgment in favor of Wildlife Services on the Wilderness Act claim but disagreed with its grant of summary judgment in favor of Wildlife Services on the NEPA claim. The Court’s decision both maintained continuity in its interpretation of the Wilderness Act as applied to PDM and distinguished the analytical requirements applicable to agency environmental assessments under NEPA.