International Society for the Protection of Mustangs and Burros v. United States Department of Agriculture

CourtDistrict Court, D. Arizona
DecidedJuly 12, 2022
Docket3:22-cv-08114
StatusUnknown

This text of International Society for the Protection of Mustangs and Burros v. United States Department of Agriculture (International Society for the Protection of Mustangs and Burros v. United States Department of Agriculture) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
International Society for the Protection of Mustangs and Burros v. United States Department of Agriculture, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8

Interna tional Society for the Protection ) No. CV-22-08114-PCT-SPL ) 9 of Mustangs and Burros, ) 10 ) O R D E R Plaintiff, ) ) 11 vs. ) ) 12 United States Department of ) 13 Agriculture, et al., ) ) ) 14 Defendants. ) 15 Before the Court is Plaintiff International Society for the Protection of Mustangs 16 and Burros’ (“Plaintiff”) Motion for Temporary Restraining Order1 (Doc. 13). Plaintiff 17 alleges that Defendants have captured and impounded certain horses found on the Apache 18 National Forest. Plaintiff asserts that Defendants plan to hold a public sale of the horses 19 and seeks a temporary restraining order (“TRO”) enjoining Defendants from doing so. 20 I. BACKGROUND 21 On June 28, 2022, Plaintiff filed a Complaint (Doc. 1), seeking declaratory relief as 22 it relates to the United States Forest Service’s alleged capture, removal, and impending sale 23 of horses found on Apache National Forest land.2 On July 12, 2022, Plaintiff filed this 24

25 1 In its request, Plaintiff asks that Defendants be called to show cause why a preliminary injunction should not issue. This improperly shifts the burden for seeking an 26 injunction, which resides with the moving party. Therefore, for purposes of this motion, the Court has treated Plaintiff’s Motion for TRO as a Motion for Preliminary Injunction 27 because the standard is the same for each.

28 2 Plaintiff has since filed an Amended Complaint (Doc. 11). 1 Motion requesting the issuance of a TRO preventing Defendants from selling the horses. 2 (Doc. 13 at 1–2). According to Plaintiff, the horses are not “unauthorized livestock”—as 3 Defendants claim—but rather wild, free-roaming horses that are federally protected. (Id. at 4 2). Plaintiff asserts that their removal and sale violates the National Environmental Policy 5 Act, the Wild Free-Roaming Horses and Burros Act of 1971, and the Administrative 6 Procedures Act. (Id. at 5). The sale of the horses is currently scheduled for July 14, 20, and 7 21, 2022. (Id. at 1). 8 II. LEGAL STANDARD AND DISCUSSION 9 A request for a TRO is analyzed under the same standards as a request for a 10 preliminary injunction. Stuhlbarg Int’l Sales Co., Inc. v. John D. Brush & Co., Inc., 240 11 F.3d 832, 839 n.7 (9th Cir. 2001). “A preliminary injunction is ‘an extraordinary and drastic 12 remedy, one that should not be granted unless the movant, by a clear showing, carries the 13 burden of persuasion.’” Lopez v. Brewer, 680 F.3d 1068, 1072 (9th Cir. 2012) (quoting 14 Mazurek v. Armstrong, 520 U.S. 968, 972 (1997) (per curiam) (emphasis omitted)); see 15 also Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 24 (2008) (citation omitted) (“A 16 preliminary injunction is an extraordinary remedy never awarded as of right”). A party 17 seeking injunctive relief under Rule 65 of the Federal Rules of Civil Procedure must show 18 that: (1) it is likely to succeed on the merits; (2) it is likely to suffer irreparable harm in the 19 absence of injunctive relief; (3) the balance of equities tips in its favor; and (4) an injunction 20 is in the public interest.3 Winter, 555 U.S. at 20; Stuhlbarg, 240 F.3d at 839, n.7; Pom 21 Wonderful LLC v. Hubbard, 775 F.3d 1118, 1124 (9th Cir. 2014); Pimentel v. Dreyfus, 670 22 F.3d 1096, 1105–06 (9th Cir. 2012). Where a movant seeks a mandatory—rather than a 23 prohibitory—injunction, the request for injunctive relief is “subject to a heightened

24 3 The Ninth Circuit observes a “sliding scale” approach, in that these elements “are 25 balanced, so that a stronger showing of one element may offset a weaker showing of another.” All. for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011). Thus, 26 by example, an injunction can issue where there are “‘serious questions going to the merits’ and a balance of hardships that tips sharply towards the plaintiff . . . so long as the plaintiff 27 also shows that there is a likelihood of irreparable injury and that the injunction is in the public interest.” Id. at 1135. 28 1 scrutiny and should not be issued unless the facts and law clearly favor the moving party.” 2 Dahl v. HEM Pharms. Corp., 7 F.3d 1399, 1403 (9th Cir. 1993).4 3 Plaintiff’s allegations that Defendants plan to sell the horses as soon as July 14, 4 2022 leads the Court to find that Plaintiff is likely to suffer irreparable harm in the absence 5 of a TRO pending a hearing on the merits of a preliminary injunction. If Plaintiff’s 6 allegations are taken as true, the captured horses are not “unauthorized livestock” that are 7 subject to capture and sale by the federal government, but rather they are wild, free-roaming 8 horses that are protected by several federal laws and that should remain in the Apache 9 National Forest. If a TRO is not issued, the horses would be sold and permanently removed 10 from their Apache National Forest habitat before any determination could be made as to 11 whether they are “unauthorized livestock” or if they are instead federally protected, wild, 12 free-roaming horses. The allegations in Plaintiff’s verified complaint demonstrate that 13 Plaintiff has a strong likelihood of success on the merits of its claims under the National 14 Environmental Policy Act, the Wild Free-Roaming Horses and Burros Act of 1971, and 15 the Administrative Procedures Act. The allegations in Plaintiff’s verified complaint also 16 demonstrate that the balance of the equities in this case clearly tips in favor of maintaining 17 the status quo. In the absence of a TRO, the horses could be sold and there would be no 18 recourse or meaningful remedy for Plaintiff, even if it is later determined—at the 19 preliminary injunction hearing or during litigation—that the horses are federally protected, 20 wild, free-roaming horses. Conversely, Defendants would not face any obvious hardship if 21 a TRO were issued because the sale of the horses could always be held at a later date if it 22 is determined that the horses are indeed “unauthorized livestock.” Finally, the Court finds 23 that a TRO would protect the public interest by maintaining the status quo until a 24 4 “A mandatory injunction orders a responsible party to take action,” while “a 25 prohibitory injunction prohibits a party from taking action and preserves the status quo pending a determination of the action on the merits.” Marlyn Nutraceuticals, Inc. v. Mucos 26 Pharma GmbH & Co., 571 F.3d 873, 879 (9th Cir. 2009) (internal quotation marks omitted). “The ‘status quo’ refers to the legally relevant relationship between the parties 27 before the controversy arose.” Ariz. Dream Act Coal. v. Brewer, 757 F.3d 1053, 1060–61 (9th Cir. 2014). 28 1 preliminary injunction hearing can be held. 2 The Court finds that Plaintiff has sufficiently met all four prongs that are required 3 for a TRO to issue. However, Plaintiff requests that the TRO issue without notice, which 4 creates an additional level of analysis for the Court. Unlike a preliminary injunction, see 5 Fed. R. Civ. P.

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Pom Wonderful v. Robert Hubbard, Jr.
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International Society for the Protection of Mustangs and Burros v. United States Department of Agriculture, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-society-for-the-protection-of-mustangs-and-burros-v-united-azd-2022.