Gescheidt v. Haaland

CourtDistrict Court, N.D. California
DecidedAugust 2, 2021
Docket4:21-cv-04734
StatusUnknown

This text of Gescheidt v. Haaland (Gescheidt v. Haaland) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gescheidt v. Haaland, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JACK GESCHEIDT, et al., Case No. 21-cv-04734-HSG 8 Plaintiffs, ORDER DENYING PLAINTIFFS’ MOTION FOR PRELIMINARY 9 v. INJUNCTION 10 DEB HAALAND, et al., Re: Dkt. No. 8 11 Defendants. 12 13 Pending before the Court is a motion for preliminary injunction, filed by Plaintiffs Jack 14 Gescheidt, Laura Chariton, Skyler Thomas, and the Animal Legal Defense Fund.1 Dkt. No. 8 15 (“Mot.”). The Court held a telephonic hearing on July 30, 2021. For the reasons detailed below, 16 the Court DENIES the motion. 17 I. BACKGROUND 18 Plaintiffs filed this action against the National Park Service (“Park Service” or “NPS”)2 on 19 June 22, 2021. See Dkt. No. 1 (“Compl.”). Plaintiffs challenge the Park Service’s management 20 practices related to the tule elk population that lives in the Tomales Point area of Point Reyes 21 National Seashore. Id. Plaintiffs contend that recent drought conditions in the area have become 22 “extremely dire,” and the tule elk are dying from lack of adequate forage and water. See, e.g., 23 id. at ¶ 1. Plaintiffs allege that the death of tule elk could be avoided through the Park Service’s 24 prompt intervention, and that the agency’s failure to timely revise its management plans and 25 1 Although styled as a motion for a temporary restraining order and preliminary injunction, during 26 the case management conference held on June 28, 2021, the parties agreed to move forward with Dkt. No. 8 as a motion for preliminary injunction. See Dkt. No. 12. 27 2 Plaintiffs sue Deb Haaland, the Secretary of the Interior, Shawn Benge, Acting Director of the 1 provide the elk with supplemental food and water violate the Administrative Procedure Act 2 (“APA”). See id. at ¶¶ 4–6. 3 A. Factual Background 4 i. History of Point Reyes National Seashore and the Tule Elk 5 The Point Reyes National Seashore operates as a unit of the National Park System and is 6 administered by the Park Service. See Pub. L. No. 94–544, 90 Stat. 2515 (1976). Congress 7 initially established the National Seashore in September 1962 to “preserve, for purposes of public 8 recreation, benefit, and inspiration, a portion of the diminishing seashore of the United States that 9 remains undeveloped.” See Pub. L. No. 87-657, 76 Stat. 538 (codified as amended at 16 U.S.C. 10 §§ 459c et seq.). The National Seashore currently includes 32,000 acres of wilderness, including 11 the area of Tomales Point where the tule elk at issue in this case live.3 See Dkt. No. 8-3, Ex. A 12 (“1998 Tule Elk Management Plan”) at 4. 13 Tule elk (Cervus elaphus nannodes) are a distinct subspecies of elk endemic to California. 14 See id. At the time the National Seashore was created, however, no tule elk were present there. 15 See id. at 8. They were extirpated from much of California by the mid-1800s due to hunting and 16 loss of habitat. Id. at 4. California began a conservation program in the 1970s to increase the 17 population across the state. Id. at 6. Congress also directed federal agencies to “cooperate with 18 the State of California in making the lands under their respective jurisdictions reasonably available 19 for the preservation and grazing of Tule elk in such manner and to such extent as may be 20 consistent with Federal law.” 16 U.S.C. § 673e. As part of this process, the California 21 Department of Fish and Game provided 10 tule elk to the Park Service in 1978 for reintroduction 22 at Tomales Point. See 1998 Tule Elk Management Plan at 8. The Park Service subsequently 23 erected a three-mile-long fence along the southern border of Tomales Point to “isolate[] the herd 24 from adjacent dairy ranches.”4 See id. This created a 2,600-acre enclosure for the elk at Tomales 25 26 3 In total, the National Seashore encompasses over 70,000 acres. See POINT REYES PARK STATISTICS, https://www.nps.gov/pore/learn/management/statistics.htm (last visited July 30, 2021). 27 4 The parties appear to agree that the fence at issue separates the elk from public lands where the 1 Point, which still exists today. Id. Although the tule elk did not initially thrive, the population at 2 Tomales Point eventually grew to over 100 by 1989. See Dkt. No. 16 (“Press Decl.”) at ¶¶ 12–15. 3 ii. The National Park Service’s Management of the Tule Elk 4 In September 1980, the Park Service issued a General Management Plan for the National 5 Seashore, which identified management objectives and strategies for management of the National 6 Seashore (the “1980 General Management Plan”).5 According to the plan, the Park Service’s 7 management objectives included “identify[ing], protect[ing], and perpetuat[ing] the diversity of 8 existing ecosystems which are found at Point Reyes National Seashore and are representative of 9 the California seacoast,” as well as “protect[ing] marine mammals, threatened and endangered 10 species, and other sensitive natural resources found within the seashore.”6 The plan also stated 11 that “[r]estoration of historical natural conditions (such as reestablishment of Tule elk) will 12 continue to be implemented when such actions will not seriously diminish scenic and recreational 13 values.”7 14 Congress also specifically directed the Secretary of the Interior to “develop a plan for Tule 15 elk restoration and conservation, including habitat management.” 16 U.S.C. § 673g. In 1998, the 16 Park Service issued a Tule Elk Management Plan. The purpose of the 1998 plan was “to guide the 17 management, monitoring, and research of the tule elk . . . at Point Reyes National Seashore for the 18 next five to ten years.” See 1998 Tule Elk Management Plan at 1. The 1998 plan identified three 19 “missions” related to the elk: 20 • Adaptively manage elk as a natural component of the dynamic 21 ecosystem of Point Reyes.

22 • Assist in the preservation of tule elk as a subspecies and the genetic diversity it contains. 23 • Manage tule elk consistent with other management objectives, 24 including agriculture, public visitation, and the protection of 25 land at the National Seashore. See 54 U.S.C. § 102102(a). 26 5 See GENERAL MANAGEMENT PLAN FOR POINT REYES NATIONAL SEASHORE – SEPTEMBER 1980, https://www.nps.gov/pore/learn/management/upload/planning_gmp_1980.pdf (last visited July 30, 27 2021). natural, cultural, and recreational resources. 1 2 Id. at 37–39. 3 As relevant to this case, the 1998 plan also adopted specific management actions, including 4 that the Park Service would “[m]aintain the elk fence on Tomales Point and continue to separate 5 tule elk from cattle”; “continue monitoring tule elk and their environment to analyze trends and 6 better understand tule elk population dynamics and ecology at Point Reyes”; and set an interim 7 population range for the “Point Reyes tule elk population at 600–800 animals, with Tomales Point 8 set at 350–450 and Limantour set at 250–350.” See id. at 43–45, 49–50. The 1998 plan stated that 9 “[r]emoving the fence at Tomales Point will be considered if and when ranching ceases on the 10 adjacent lands.” Id. at 49. The plan also explicitly rejected the idea of providing supplemental 11 forage for the tule elk, specifying that “[n]o effort will be made to cultivate food crops specifically 12 to improve the range’s ability to support elk.” Id. at 44. The Park Service reasoned that “[s]uch 13 strategies are known to be self-defeating as artificially provided food leads to ever-increasing herd 14 sizes that overwhelm the ability of the range to support them.” Id.

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Bluebook (online)
Gescheidt v. Haaland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gescheidt-v-haaland-cand-2021.