Carter Reservoir Mustangs, Inc. et al. v. United States Department of Interior et al.

CourtDistrict Court, E.D. California
DecidedJuly 8, 2026
Docket2:25-cv-03252
StatusUnknown

This text of Carter Reservoir Mustangs, Inc. et al. v. United States Department of Interior et al. (Carter Reservoir Mustangs, Inc. et al. v. United States Department of Interior et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carter Reservoir Mustangs, Inc. et al. v. United States Department of Interior et al., (E.D. Cal. 2026).

Opinion

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 ----oo0oo---- 11 12 CARTER RESERVOIR MUSTANGS, INC., No. 2:25-cv-3252 WBS DMC 13 et al.,

14 Plaintiffs, MEMORANDUM AND ORDER RE: 15 v. MOTION FOR PRELIMINARY INJUNCTION 16 UNITED STATES DEPARTMENT OF INTERIOR, et al., 17 Defendants. 18

19 ----oo0oo---- 20 This case involves claims brought pursuant to several 21 federal statutes challenging Bureau of Land Management (“BLM”) 22 decisions regarding the relocation of wild horses. (See First 23 Am. Compl. (“FAC”) (Docket No. 12).) Plaintiffs now move for 24 preliminary injunctive relief on the ten claims they raise in the 25 FAC. (Docket No. 22.) Specifically, they seek to temporarily 26 halt a scheduled removal of so-called excess wild horses in 27 Northeastern California. (Id. at 10.) 28 1 I. Background 2 Plaintiffs primarily challenge BLM’s 2025 Gather Plan 3 and its scheduled execution. The 2025 Gather Plan authorizes the 4 “gather and removal” of wild horses in three locations, called 5 Herd Management Areas (“HMAs”): the Carter Reservoir HMA, the 6 Buckhorn HMA, and the Coppersmith HMA.1 (FAC at 24.) BLM 7 arrived at this plan by relying upon “Appropriate Management 8 Levels” (“AMLs”) for wild horses. (Id.) An AML is the 9 population of wild horses that a given area of land can sustain. 10 (Id.) The relied-upon AMLs have their own histories: They were 11 “set, modified, or reaffirmed” through the “1981 Cowhead/Massacre 12 Land Use Plan MFP,2 1985/1989 Carter Reservoir HMA Herd 13 Management Area Plan, 2003 Carter Reservoir AML 14 Establishment/Capture Plan, . . . 2008 Surprise Resource 15 Management Plan,” the 1984 Coppersmith Herd Management Area Plan, 16 and the 1984 Buckhorn Herd Management Area Plan, many of which 17 plaintiffs also challenge. (Id. at 24—25, 31—32.) 18 a. The Carter Reservoir HMA 19 The Cowhead/Massacre Land Use Plan, which BLM adopted 20 in 1981, addressed 769,000 acres of public land and established 21 the Carter Reservoir HMA. (Id. at 25—26.) In establishing the 22 Carter Reservoir HMA as part of this plan, BLM stated that 23

24 1 The FAC contains a veritable herd of acronyms scattered throughout its body. The court – which is not a subject-matter 25 expert in agency action regarding the management of wild horses - - finds these acronyms challenging to wrangle. 26

27 2 An “MFP” is defined in the instant motion as a Management Framework Plan. (Docket No. 22 at 11.) 28 1 “40,000 acres would be provided for a total population of 20 to 2 30 horses,” with 300 Animal Unit Months (“AUMs”) of forage. (Id. 3 at 26.) An AUM is defined by BLM as “the amount of forage 4 necessary to sustain one adult horse . . . for one month.” (Id. 5 at 12.) Plaintiffs allege that the AML of 20 to 30 horses was 6 “not based on evidence, analysis or appropriate studies” and 7 “improperly limited” to the “geographic area” of 40,000 acres. 8 (Id.) They further allege that, in selecting the boundaries for 9 the Carter Reservoir HMA, BLM failed to “take into account water 10 resources needed to sustain a viable horse population.” (Id. at 11 27.) 12 In 1985, BLM adopted a HMAP for the Carter Reservoir 13 HMA, specifically. (Id.) Pursuant to this plan, BLM reduced the 14 acreage of the Carter Reservoir HMA from 40,000 to 23,200 15 “without any analysis, rationale, or discussion.” (Id.) BLM did 16 not, however, alter its 1981 AML of 20 to 30 horses in its 1985 17 HMAP. (Id.) Nor did it explain why. (See id. at 27—28.) 18 BLM revised some provisions of the Carter Reservoir 19 HMAP in 1989 but did not modify the Carter Reservoir HMA’s 20 boundaries or AML. (Id. at 28.) In 2003, BLM adopted the 21 “Carter Reservoir AML Establishment/Capture Plan,” which 22 increased the AML for the Carter Reservoir HMA from 20 to 30 wild 23 horses to 25 to 35 wild horses. (Id.) Plaintiffs allege that, 24 in arriving at this increased AML in 2003, BLM failed to 25 “consider habitat suitability,” namely, the lack of available 26 vegetation and water for the wild horses during the winter 27 months. (See id. at 28—29.) 28 1 Five years later, BLM adopted the 2008 Surprise 2 Resource Management Plan. (Id. at 30.) This plan did not alter 3 the 2003 AML for wild horses in the Carter Reservoir HMA, nor did 4 it analyze whether the Carter Reservoir was a suitable habitat 5 for wild horses, and, if not, whether the HMA should have been 6 enlarged or altered. (See id.) 7 b. The Coppersmith and Buckhorn HMAs 8 In 1979, BLM adopted the Tuledad/Home Camp Management 9 Framework Plan, which established an AML of 80 to 100 horses for 10 the Tuledad HMA. (Id. at 30.) BLM established this AML by, 11 among other things, considering available land and forage. (See 12 id.) 13 Four years later, the Tuledad HMA was divided into the 14 Coppersmith HMA and Buckhorn HMA. (Id.) After meeting with 15 interested individuals, BLM and those individuals informally 16 agreed that an AML of 50 to 75 horses would be appropriate for 17 the Coppersmith HMA and the Buckhorn HMA, each. (See id.) 18 In 1984, BLM adopted a HMAP for the Coppersmith HMA 19 that affirmed, but did not re-evaluate, the AML of 50 to 75 20 horses informally agreed to the previous year. (See id. at 31) 21 BLM did the same in creating a HMAP for the Buckhorn HMA. (See 22 id.) 23 c. The 2025 Gather Plan 24 Last year, BLM adopted the Carter Reservoir, Buckhorn, 25 and Coppersmith Wild Horse Gather and Population Control Plan, 26 known as the 2025 Gather Plan. (Id.) The 2025 Gather Plan 27 28 1 provides for the “gather and removal of” hundreds of “excess wild 2 horses” in the previously-described HMAs. (See id. at 24.) 3 According to plaintiffs, this plan did not involve the 4 adjustment or re-calculation of the above-described AMLs. (See 5 id. at 32.) Rather, the 2025 Gather Plan contained a 6 “determination that an overpopulation [of wild horses] exists in 7 the Carter Reservoir, Buckhorn, and Coppersmith HMAs,” the 8 corresponding AMLs for which plaintiffs allege were “not based on 9 appropriate evidence, studies, and analysis; and/or were based on 10 acreage different from that addressed in earlier land use plans 11 and decisions.” (Id.) Plaintiffs then detail the further, 12 allegedly deficient actions BLM took (or did not take) in 13 adopting the 2025 Gather Plan. (See id. at 32—33.) 14 d. Executing the 2025 Gather Plan 15 On March 13, 2026, BLM solidifed its plans to 16 operationalize the 2025 Gather Plan. (See Docket No. 22 at 25.) 17 Specifically, BLM aims to gather and remove 470 wild horses from 18 the Carter Reservoir HMA, 273 wild horses from the Buckhorn HMA, 19 and 113 wild horses from the Coppersmith HMA. (Id.) These 20 gathers, which the court will refer to as the September 2026 21 Gathers, are currently scheduled to be executed between September 22 1, 2026, and September 30, 2026. (Id.) 23 Plaintiffs seek to preliminarily enjoin the September 24 2026 Gathers on the grounds that they violate the Wild Free- 25 Roaming Horses and Burros Act (WHA), 16 U.S.C. § 1332, et seq.; 26 the Federal Land Policy and Management Act (FLMPA), 43 U.S.C. § 27 1701 et seq.; the National Environmental Policy Act (NEPA), 42 28 1 U.S.C. § 4321 et seq.; and the Administrative Procedure Act 2 (APA), 5 U.S.C. § 551 et seq. (Docket No. 22 at 2.) Defendants 3 oppose plaintiffs’ motion. (Docket No. 32.) 4 II. The Plaintiffs 5 Plaintiffs consist of (1) a nonprofit, Carter Reservoir 6 Mustangs, Inc.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Warth v. Seldin
422 U.S. 490 (Supreme Court, 1975)
Amoco Production Co. v. Village of Gambell
480 U.S. 531 (Supreme Court, 1987)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
DaimlerChrysler Corp. v. Cuno
547 U.S. 332 (Supreme Court, 2006)
Bartlett v. Strickland
556 U.S. 1 (Supreme Court, 2009)
Butte County, Cal. v. Hogen
613 F.3d 190 (D.C. Circuit, 2010)
Mazurek v. Armstrong
520 U.S. 968 (Supreme Court, 1997)
Fund for Animals, Inc. v. Espy
814 F. Supp. 142 (District of Columbia, 1993)
Fund for Animals v. Clark
27 F. Supp. 2d 8 (District of Columbia, 1998)
Gifford v. Lone Star Steel Co.
2 F. Supp. 2d 909 (E.D. Texas, 1997)
Fund for Animals v. Norton
281 F. Supp. 2d 209 (District of Columbia, 2003)
United States v. Ayala-Vazquez
751 F.3d 1 (First Circuit, 2014)
New York v. Adamowicz
16 F. Supp. 3d 123 (E.D. New York, 2014)
Alliance for Wild Rockies v. Cottrell
632 F.3d 1127 (Ninth Circuit, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Carter Reservoir Mustangs, Inc. et al. v. United States Department of Interior et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/carter-reservoir-mustangs-inc-et-al-v-united-states-department-of-caed-2026.