Friends of Animals v. United States Bureau of Land Management

CourtCourt of Appeals for the D.C. Circuit
DecidedFebruary 20, 2026
Docket24-5155
StatusPublished

This text of Friends of Animals v. United States Bureau of Land Management (Friends of Animals v. United States Bureau of Land Management) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Friends of Animals v. United States Bureau of Land Management, (D.C. Cir. 2026).

Opinion

United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT

Argued October 1, 2025 Decided February 20, 2026

No. 24-5155

FRIENDS OF ANIMALS, APPELLANT

v.

UNITED STATES BUREAU OF LAND MANAGEMENT, AN AGENCY OF THE UNITED STATES AND STATE OF UTAH, APPELLEES

Appeal from the United States District Court for the District of Columbia (No. 1:18-cv-02029)

Jennifer Best argued the cause for appellant. With her on the briefs was Stephen Hernick.

Ezekiel A. Peterson, Attorney, U.S. Department of Justice, argued the cause for appellee U.S. Bureau of Land Management. With him on the brief were Adam R.F. Gustafson, Acting Assistant Attorney General, and Robert Lundman, Attorney. Rebecca Jaffe, Attorney, entered an appearance.

Steve Geary, Assistant Solicitor General, Office of the 2 Attorney General for the State of Utah, argued the cause for appellee State of Utah. With him on the brief were Derek Brown, Attorney General, and Stanford Purser, Solicitor General.

Before: KATSAS and CHILDS, Circuit Judges, and EDWARDS, Senior Circuit Judge.

Opinion for the Court filed by Senior Circuit Judge EDWARDS.

EDWARDS, Senior Circuit Judge: The Wild Free-Roaming Horses and Burros Act, 16 U.S.C. §§ 1331-1340 (the “Act”), authorizes and directs the Bureau of Land Management (“BLM”) “to protect and manage wild free-roaming horses and burros as components of the public lands.” Id. § 1333(a). Pursuant to this role, BLM is responsible for culling the wild horse population on public lands to promote their long-term sustainability. In assuming this responsibility, BLM is obliged to adhere to certain statutory requirements that were enacted to ensure the protection of wild horses.

The dispute in this case is focused on “ten-year plans” that were issued by BLM to manage wild horse populations on public lands. These plans authorize BLM to gather and remove wild horses from four different geographic areas during the course of a ten-year period. In August 2018, Appellant, Friends of Animals, filed a lawsuit in the District Court against BLM under the Administrative Procedure Act (“APA”) initiating a challenge to the ten-year plans. In pursuing this action, Appellant claimed that the contested plans should be struck down because they impermissibly “allow BLM to conduct an indefinite number of subsequent removals of wild horses despite (1) not identifying a specific overpopulation or excess horses that need to be removed, (2) not making excess 3 determinations based on current information, and (3) not consulting with independent parties.” Appellant’s Br. 2. According to Appellant, “[n]othing in the [Act] . . . authorizes BLM to issue long-term, open-ended [plans] to continually roundup and remove an undisclosed number of wild horses at unknown times over the course of ten years.” Id. at 23. BLM responded that nothing in the Act prohibits it from authorizing multiple gathers over a period of years in a single plan.

The District Court found merit in some of the claims advanced by Appellant. In particular, the court held unlawful and vacated each of the contested ten-year plans to the extent that each authorized additional gathers after the plan has achieved the stated population goal for a specified geographic area. See Friends of Animals v. BLM, 728 F. Supp. 3d 45, 80- 81 (D.D.C. 2024). No party contests this judgment. The District Court also held that the ten-year plans are unlawful to the extent they authorize future gathers that disregard the Act’s “duty to act promptly and to ensure that gather decisions are informed by current information and consultation.” Id. at 81. No party contests this judgment. The District Court then remanded the case to BLM to “revise” each of the contested plans “to clarify which future gathers will require further process before they can proceed.” Id. at 79 (citation omitted); see also Joint Appendix (“J.A.”) 406. Therefore, the parties’ principal disagreements were left unresolved by the District Court pending remand.

Appellant now appeals, seeking to invoke this court’s jurisdiction under 28 U.S.C. § 1291. However, that section limits our jurisdiction to “final decisions of the district courts of the United States,” 28 U.S.C. § 1291 (emphasis added), and controlling case law instructs us that “a district court’s remand order is not normally ‘final’ for purposes of appeal under 28 U.S.C. § 1291,” N.C. Fisheries Ass’n, Inc. v. Gutierrez, 550 4 F.3d 16, 19 (D.C. Cir. 2008) (citations omitted). In this case, the District Court ordered BLM to reconsider Appellant’s claims on remand. BLM must “adopt reasonable limitations regarding when (and with what information in hand) it may conduct follow-on gathers before achieving [the target population] for each of the four [ten-year plans].” J.A. 406; see also Friends of Animals, 728 F. Supp. 3d at 81.

The District Court’s order remanding the case to the agency was not a final decision under 28 U.S.C. § 1291. Therefore, on the record before us, we are required to dismiss this appeal for lack of subject-matter jurisdiction.

I. BACKGROUND

A. Wild Free-Roaming Horses and Burros Act

Congress enacted the Wild Free-Roaming Horses and Burros Act in 1971 to preserve and protect wild free-roaming horses and burros. Congress believed that doing so would “enhance and enrich the dreams and enjoyment of future generations of Americans.” H.R. REP. NO. 92-681, at 7 (1971) (Conf. Rep.). To that end, the 1971 enactment only permitted BLM to destroy horses or burros “because of overpopulation” if it determined that “such action [was] the only practical way to remove excess animals from the area.” Pub. L. No. 92-195 § 3(c), 85 Stat. 649, 650 (1971).

Congress soon realized that the 1971 law may have overreached in pursuing its goal of protecting wild horses and burros. The legislative history underlying the 1978 amendments to the Act notes that wild horses and burros had “exceed[ed] the carrying capacity of the range” and “pose[d] a threat to their own habitat” as well as other wildlife and rangeland values. H.R. REP. NO. 95-1122, at 2 (1978). 5 Although Congress remained committed to “protecting wild free-roaming horses and burros from capture, branding, harassment, or death,” it also recognized the necessity of “facilitating the removal and disposal of excess wild free- roaming horses and burros.” Id. Congress enacted the 1978 amendments to serve both goals.

The amended Act directs BLM, as delegate for the Secretary of the Interior, to “protect and manage wild free- roaming horses and burros . . . in a manner that is designed to achieve and maintain a thriving natural ecological balance on the public lands.” 16 U.S.C. § 1333(a); see also id. § 1332(a). To carry out these responsibilities, the Act tasks BLM with “maintain[ing] a current inventory of wild free-roaming horses and burros” in order to:

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Friends of Animals v. United States Bureau of Land Management, Counsel Stack Legal Research, https://law.counselstack.com/opinion/friends-of-animals-v-united-states-bureau-of-land-management-cadc-2026.