Arizona State Legislature v. Biden

CourtCourt of Appeals for the Ninth Circuit
DecidedApril 1, 2026
Docket25-1370
StatusUnpublished

This text of Arizona State Legislature v. Biden (Arizona State Legislature v. Biden) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arizona State Legislature v. Biden, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 1 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

ARIZONA STATE LEGISLATURE, by No. 25-1370 and through the President of the Arizona D.C. Nos. Senate, Warren Petersen, and the Speaker of 3:24-cv-08026-SMM the Arizona House of Representatives, Steve 3:24-cv-08027-SMM Montenegro; KIMBERLY YEE, in her official capacity as Treasurer of the State of MEMORANDUM* Arizona; COUNTY OF MOHAVE; TOWN OF COLORADO CITY, Arizona; TOWN OF FREDONIA, Arizona,

Plaintiffs - Appellants,

v.

JOSEPH R. BIDEN, in his official capacity as President of the United States; DEB HAALAND, in her official capacity as Secretary of the Interior; UNITED STATES DEPARTMENT OF THE INTERIOR; TRACY STONE-MANNING, in her official capacity as Director of the Bureau of Land Management; UNITED STATES BUREAU OF LAND MANAGEMENT; TOM VILSACK, in his official capacity as Secretary of Agriculture; UNITED STATES DEPARTMENT OF AGRICULTURE,

Defendants - Appellees,

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. STATE OF ARIZONA; KATIE HOBBS, Governor of Arizona,

Intervenor-Defendants - Appellees.

Appeal from the United States District Court for the District of Arizona Stephen M. McNamee, District Judge, Presiding

Argued and Submitted February 3, 2026 Phoenix, Arizona

Before: CALLAHAN, OWENS, and FRIEDLAND, Circuit Judges.

This appeal arises from a challenge to a presidential proclamation (the

“Proclamation”) that created a national monument in Arizona pursuant to the

President’s authority under the Antiquities Act of 1906. See Establishment of the

Baaj Nwaavjo I’tah Kukveni Ancestral Footprints of the Grand Canyon National

Monument, 88 Fed. Reg. 55331 (Aug. 8, 2023); 54 U.S.C. §§ 320301-303. The

Proclamation prohibits all mining, mineral leasing, and geothermal leasing on

monument land, 88 Fed. Reg. at 55339, although mining on the land had already

been prohibited since 2012 under a ban issued by the Department of the Interior

that is set to last until 2032, or later if it is extended (the “2012 Withdrawal”), see

Public Land Order No. 7787, 77 Fed. Reg. 2563 (Jan. 18, 2012); 43 U.S.C. § 1714

(allowing extensions of federal land withdrawals). The monument is located on

federal land, but it touches or surrounds some parcels of state land. See 88 Fed.

2 25-1370 Reg. at 55343-44.

Plaintiffs-Appellants are the Arizona State Legislature, the Arizona State

Treasurer, and three local governments in Arizona—Mohave County, Colorado

City, and the Town of Fredonia. Plaintiffs sued the President as well as several

other federal officers, seeking to have the Proclamation set aside, and the State of

Arizona and the Governor of Arizona intervened as Defendants. Plaintiffs allege

that the Proclamation injures them in numerous ways, but the district court

dismissed Plaintiffs’ Complaint, concluding that none of them had standing. We

have jurisdiction under 28 U.S.C. § 1291. Reviewing de novo, Barke v. Banks, 25

F.4th 714, 718 (9th Cir. 2022), we affirm.

1. The three local governments allege a future injury from lost tax revenue

that they hoped to collect from companies that would mine uranium once the 2012

Withdrawal lapses. To qualify as an “injury in fact” for purposes of establishing

standing, a future injury must be “imminent,” not “speculative.” Clapper v.

Amnesty Int’l USA, 568 U.S. 398, 409 (2013) (citation modified). Thus,

“allegations of possible future injury are not sufficient.” Id. (citation modified).

When the plaintiff’s injury depends on “unfettered choices” made by third parties,

“standing is not precluded, but it is ordinarily substantially more difficult to

establish.” Lujan v. Defs. of Wildlife, 504 U.S. 555, 562 (1992) (citation

modified).

3 25-1370 Under those principles, the local governments’ alleged injury is insufficient

for standing. Their alleged loss of future tax revenue depends on uranium prices

being sufficiently high in 2032 (or whenever the 2012 Withdrawal lapses) such

that third-party companies would choose to begin mining. But it is speculative

whether the right economic conditions and incentives for uranium mining will exist

so far into the future. Accordingly, the allegations amount to only a “possible

future injury.” Clapper, 568 U.S. at 409.

To the extent the local governments allege that, separate and apart from

anticipated uranium mining, they are presently losing tax revenue from the ban on

mineral and geothermal leasing, that injury is equally speculative. Plaintiffs fail to

allege that any entity has ever sought to engage in “mineral or geothermal leasing,”

or that the monument land even contains those resources.

2. Colorado City alleges that the Proclamation “threatens [its] water supply”

because some of its water comes from an aquifer located under the monument and

federal actors may decide to “restrict[]” that water supply in the future. Those

allegations are similarly insufficient for standing. The Proclamation by its plain

terms does not “alter the valid existing water rights of any party, including the

United States,” 88 Fed. Reg. at 55339, and there is otherwise no reason to

speculate that the federal government will “reduce Colorado City’s water supply,”

as Colorado City fears. See Clapper, 568 U.S. at 416 (holding that plaintiffs

4 25-1370 “cannot manufacture standing . . . based on their fears of hypothetical future harm

that is not certainly impending”).

3. The Arizona Legislature asserts that it is injured because (1) the

Proclamation “strips [it] of its prerogative” power to sell, lease, and set royalty

rates for state land, particularly the parcels surrounded by the monument, and

(2) the Proclamation allegedly reduces the value of nearby state land and deprives

the state of tax revenue it could collect from companies who would develop the

land. The State Treasurer alleges the second injury as well, observing that the

Treasurer has a “role in ensuring that Arizona receives the highest and best value”

for its state land. Neither injury suffices for standing.

With respect to the first injury, contrary to the Legislature’s assertion, the

Proclamation does not strip the Legislature of any of its powers—the Legislature

may continue to manage and dispose of state land as it sees fit. See 88 Fed. Reg. at

55338-42; see also Newdow v. U.S. Cong., 313 F.3d 495, 498-99 (9th Cir. 2002)

(holding that a legislature does not suffer a “concrete and particularized” injury

where its “own ‘powers and responsibilities’ are not really under attack”).

Essentially, the Legislature alleges that the Proclamation may change the content

of future legislation regarding state land, but a legislature “suffers no legally

cognizable injury from changes to the content of legislation its future members

may elect to enact.” Va. House of Delegates v.

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Clapper v. Amnesty International USA
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Hollingsworth v. Perry
133 S. Ct. 2652 (Supreme Court, 2013)
Virginia House of Delegates v. Bethune-Hill
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Jeffrey Barke v. Eric Banks
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Newdow v. U.S. Congress
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Arizona State Legislature v. Biden, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arizona-state-legislature-v-biden-ca9-2026.