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Case Summary Citation

San Luis Obispo Coastkeeper v. Cnty. of San Luis Obispo, 161 F.4th 590 (9th Cir. 2025)

Abstract

In San Luis Obispo Coastkeeper v. Cnty. of San Luis Obispo, the Ninth Circuit addressed how to consider a mandatory preliminary injunction for an Endangered Species Act claim when multiple listed species may be affected by the requested relief. The Plaintiffs brought ESA and state law claims to compel the County of San Luis Obispo to change its operation of the Lopez Dam on Arroyo Grande Creek, which they claimed adversely affected South-Central California Coast steelhead trout. The tidewater goby and California red-legged frog, both listed species, are also present in Arroyo Grande Creek. The Ninth Circuit determined the full Winter test for a mandatory preliminary injunction is proper under these circumstances, however, when weighing public interest and equity factors, only those related to listed species are applicable.

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