Leigh v. Raby

CourtDistrict Court, D. Nevada
DecidedJanuary 28, 2022
Docket3:22-cv-00034
StatusUnknown

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

Bluebook
Leigh v. Raby, (D. Nev. 2022).

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * *

6 LAURA LEIGH, et al., Case No. 3:22-cv-00034-MMD-CLB

7 Plaintiffs, ORDER v. 8 JON RABY, et al., 9 Defendants. 10 11 I. SUMMARY 12 This action arises from a U.S. Bureau of Land Management gather of wild horses 13 in eastern Nevada. Plaintiffs Laura Leigh, Wild Horse Education, Animal Wellness Action, 14 and CANA Foundation have filed a motion for temporary restraining order and preliminary 15 injunction to stop the gather (ECF Nos. 4, 6 (“Motion”)),1 arguing that the government’s 16 actions violated the Wild Free-Roaming Horses and Burros Act (“Wild Horse Act”), 16 17 U.S.C. § 1331, et seq., and the National Environmental Policy Act of 1969 (“NEPA”), 42 18 U.S.C. § 432, et seq., and must be enjoined pending compliance. Plaintiffs further argue 19 that the government has infringed their First Amendment right to observe the gather by 20 unlawfully obstructing their access.2 Because the Court finds Plaintiffs are unlikely to 21 22

23 1In accordance with the Court’s Local Rules requiring requests for separate relief be separately filed, Plaintiffs filed their motion for temporary injunction (ECF No. 4) and 24 motion for preliminary injunction (ECF No. 6) as separate entries on the docket. See LR IC 2-2(b) (“For each type of relief requested or purpose of the document, a separate 25 document must be filed and a separate event must be selected for that document.”). The documents are identical, and the Court considers Defendants’ response brief (ECF No. 26 18) as applicable to both motions.

27 2Plaintiffs requested emergency ex parte relief. The Court found that Plaintiffs had not shown ex parte relief was required, but set an expedited briefing schedule and ordered 28 Plaintiffs to serve Defendants, which they did, and set a hearing for two days later. (ECF No. 8.) Defendants filed their response brief (ECF No. 18), and Plaintiffs made their 2 interest weigh against enjoining the Gather, the Court will deny the Motion. 3 II. BACKGROUND 4 On January 11, 2022, the U.S. Bureau of Land Management initiated a gather of 5 wild horses on the Pancake Complex in eastern Nevada (the “Gather” or “2022 Gather”). 6 (ECF No. 4 at 10.) Plaintiffs are three non-profits and one individual who work to protect 7 wild horses and Defendants are the U.S. Department of Interior, the Bureau of Land 8 Management (“BLM”), and Nevada BLM Director Jon Raby. 9 A. The Pancake Complex Herds 10 The Pancake Complex is an area west-southwest of Ely, Nevada. (Exh. B, ECF 11 No. 4-2 at 16.) It consists of two Herd Management Areas (“HMAs”), one Herd Area 12 (“HA”), and one Wild Horse Territory. (ECF No. 18 at 5.) Before the beginning of the 2022 13 Gather, the population estimate for the entire Pancake Complex was 3,244 wild horses. 14 (ECF No. 18-1 at 3.) This number is far in excess of the established cumulative 15 appropriate management level (“AML”) range for the Pancake Complex, which is only 16 361-638 wild horses. (Exh. B, ECF No. 4-2 at 17; ECF No. 18-1 at 3.) The Pancake 17 Complex AML range was established in 2008 through the decision-making process of the 18 Ely District Resource Management Plan (“RMP”). (Exh. B, ECF No. 4-2 at 17.) 19 The BLM reports that conditions on the Pancake Complex are dire. The birth rate 20 of foals is substantially down, which the BLM attributes to lack of resources mares need 21 to feed. (ECF No. 18-1 at 3.) Horses observed in the area in the past two weeks have 22 shown extremely low “body condition scores,” indicating poor health. (Id.) Severe drought 23 from the past two years has deprived the area of needed water and forage, for horses 24 and other animals on the range alike. (Id. at 2; Exh. 3, ECF No. 18-2 at 11-12; Exh. 5, 25 ECF No. 18-2 at 2.) As a result of these conditions, the BLM conducted an emergency 26 horse gather in 2020. (ECF No. 18-1 at 2.) The BLM predicts that without another gather, 27 “[w]ild horse populations would remain over appropriate management levels[,] [t]he 28 impacts to vegetation by grazing or trampling would increase more exponentially[,] . . . 2 health, and wild horses would be more susceptible to disease and drought.” (Exh. B, ECF 3 No. 4-2 at 65.) Due to ongoing drought conditions and animals leaving the Pancake 4 Complex in search of better conditions, a wild horse gather has become “an Ely District 5 priority.” (ECF No. 18-1 at 2.) 6 B. The Environmental Assessment 7 The BLM published its final Environmental Assessment (“EA”) of the planned 8 Pancake Complex Wild Horse Gather on May 5, 2021. (Exh. B, ECF No. 4-2 at 13-208.) 9 The EA included a description of the BLM’s intended action, or “Proposed Action,” 10 justifications for the Proposed Action, and considered alternatives. (Id.) Per the EA, the 11 BLM’s Proposed Action is: 12 Over a 10 year period, use phased gathers to removed excess animals in order to achieve and maintain the population within AML range, apply 13 fertility control methods (vaccines and/or IUDs) to released mares, maintain a sex ratio adjustment of 60% male and 40% female, and release a small 14 non-reproducing component of males (up to 138 geldings) that brings the population to mid-AML. 15 16 (Id. at 22.) The stated purpose of the Proposed Action “is to gather and remove excess 17 wild horses from within and outside the Pancake Complex and reduce the wild horse 18 growth rates to achieve and maintain established AML ranges.” (Id. at 19.) More 19 specifically, the Proposed Action “would be to gather and remove approximately 2,342 20 excess wild horses within the Complex to achieve and maintain AML and administer or 21 booster population control measures to gathered and released horses over a period of 22 ten years from the initial gather.” (Id. at 22.) Such action would ostensibly meet the BLM’s 23 goal of “attaining a herd size that is at the low range of AML, reducing population growth 24 rates, and achieving a thriving natural ecological balance on the range.” (Id.) Because “[i]t 25 is expected that gather efficiencies and holding space during the initial gather would not 26 allow for the removal of sufficient excess animals during the initial gather to reach or 27 maintain low AML,” the BLM anticipated needing to conduct “follow-up gathers” “on a 28 periodic basis.” (Id. at 22-23.) 2 Plaintiff Leigh (as an individual and as president of Wild Horse Education) 3 submitted comments on the preliminary EA draft on November 23, 2020. (Exh. A, ECF 4 No. 4-2 at 6-10.) Specifically, Leigh objected to the BLM’s combination of proposed gather 5 plans and broader BLM goals of herd population management. (Id. at 7.) Leigh argued 6 that if the BLM sought to enact broader goals, they should develop a Herd Management 7 Area Plan (“HMAP”). (Id.) Leigh also argued that the preliminary EA relied on data from 8 the 2008 Ely District RMP, which she claimed is now outdated and lacks in-depth area 9 analysis. (Id.) 10 The BLM noted that it received and considered over 3,600 public comments before 11 issuing the final EA.3 (Exh. B, ECF No. 4-2 at 73.) These comments and the BLM’s 12 responses were summarized in Appendix XIII of the final EA. (Id. at 169-207.) Twelve of 13 the comments were expressly attributed to Leigh, including comments arguing that the 14 EA was an improper form to proceed with a gather plan absent an HMAP and that the 15 data relied on in the EA was out of date. (Id. at 173-176, 182-184, 202.) The Bristlecone 16 and Tonopah BLM Field Office Managers reviewed the final EA and issued a Finding Of 17 No Significant Impact (“FONSI”) on May 4, 2021. (Exh. D, ECF No.

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Leigh v. Raby, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leigh-v-raby-nvd-2022.