MAHLER v. UNITED STATES FOREST SERVICE

CourtDistrict Court, S.D. Indiana
DecidedDecember 23, 2024
Docket4:24-cv-00174
StatusUnknown

This text of MAHLER v. UNITED STATES FOREST SERVICE (MAHLER v. UNITED STATES FOREST SERVICE) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MAHLER v. UNITED STATES FOREST SERVICE, (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA NEW ALBANY DIVISION

ANDY MAHLER, ) LINDA LEE, ) SHANE MURPHY, ) ROBBIE HEINRICH, ) HEARTWOOD, ) PROTECT OUR WOODS, ) INDIANA FOREST ALLIANCE INC, ) ) Plaintiffs, ) ) v. ) Case No. 4:24-cv-00174-TWP-KMB ) UNITED STATES FOREST SERVICE, ) THOMAS J. VILSACK in his official capacity as ) Secretary of the Department of Agriculture, ) UNITED STATES DEPARTMENT OF ) AGRICULTURE, ) RANDY MOORE in his official capacity as Chief ) of the United States Forest Service, ) ) Defendants. )

ORDER DENYING PLAINTIFFS' MOTION FOR TEMPORARY RESTRAINING ORDER AND DEFENDANTS' MOTION TO CONVERT This matter is before the Court on Plaintiffs Andy Mahler ("Mr. Mahler"), Linda Lee, Shane Murphy, Robbie Heinrich, Heartwood, Protect Our Woods, and Indiana Forest Alliance Inc.'s (collectively, "Plaintiffs") Motion for Temporary Restraining Order ("TRO") (Filing No. 8) and Defendants the United States Forest Service (the "Forest Service"), Thomas J. Vilsack, the United States Department of Agriculture, and Randy Moore's (collectively, "Defendants") Motion to Convert Plaintiffs' Motion for a Temporary Restraining Order to a Motion for Preliminary Injunction and to Set a Briefing Schedule (Filing No. 12). For the reasons discussed below, Plaintiffs' TRO is denied, and Defendants' Motion to Convert is denied as moot. The parties are directed to meet with the Magistrate Judge to discuss Plaintiffs' pending Motion for Preliminary Injunction, as previously ordered (Filing No. 10). I. BACKGROUND The Plaintiffs are three forest protection organizations, and four individuals including neighboring landowners and regular users of the Hoosier National Forest. (Filing No. 1 at 1).

Plaintiffs seek to enjoin the Forest Service from carrying out logging and construction work in the Hoosier National Forest as part of the Paoli Tornado Response and Research Project (the "Paoli Project") (Filing No. 8-1 at 1). Plaintiffs challenge the Paoli Project under the National Environmental Policy Act ("NEPA"), 42 U.S.C. §§ 4321–47. The NEPA, in part, requires agencies to create a report on the environmental impact of their proposed actions, called an "environmental impact statement", whenever the proposed action significantly affects the quality of a human environment. 42 U.S.C. § 4332(2)(C). If it is uncertain whether the proposed action will significantly impact the environment, the agency must prepare an "environmental assessment" ("EA"). 40 C.F.R. §§ 1501.3, 1501.5. "An EA has been described as a 'rough-cut, low-budget environmental impact statement designed to show whether a full-fledged [environmental impact

statement]—which is very costly and time-consuming to prepare and has been the kiss of death to many a federal project—is necessary." Ind. Forest Alliance, Inc. v. U.S. Forest Serv., 325 F.3d 851, 856 (7th Cir. 2003). However, federal law provides that certain agency actions fall within categorical exclusions ("CE") to the EA/ environmental impact statement requirements. An agency action can be a CE "only if there are no extraordinary circumstances related to the proposed action." 36 C.F.R. § 220.6(a). "Those extraordinary circumstances include the presence of historical and cultural sites, the potential for impacts on endangered or threatened species, the presence of caves and karst environmental features, the potential for adverse impacts on migratory birds, and the segmentation of the Paoli Project out of the larger Buffalo Springs project." (Filing No. 8-1 at 2). In 2021, the Forest Service began the "NEPA scoping process" for a separate project not at issue in this case, the "Buffalo Springs Project." The Forest Service issued an EA for that project

in 2022. Id. at 6. In 2023, severe storms and tornadoes swept across southern Indiana and damaged areas in the Hoosier National Forest. In response, the Forest Service began the NEPA scoping process for the Paoli Project. Id. The Paoli Project falls within the geographical boundaries of the Buffalo Springs Project. According to Plaintiffs, the Forest Service did not initially advise the public that it intended to rely on CEs to make its decisions for the Paoli Project. Id. Plaintiffs submitted comments and objections to the Paoli Project in January 2024. In August 2024, the Forest Service issued a Decision Memo approving the Paoli Project, stating that the decision was appropriately categorically excluded from the EA/environmental impact statement requirements and that no extraordinary circumstances existed related to the proposed action. Id. at 7. In late October 2024, Plaintiffs began corresponding with the Forest Service regarding

potential litigation over the Paoli Project. Id. On November 4, 2024, the Forest Service notified Plaintiffs that it intended to proceed with contracting the Paoli Project work. A few days later, Plaintiffs indicated that they "may decide it is necessary to file their federal court Complaint and seek an immediate injunction." Id. at 8. On November 13, 2024, the Forest Service informed Plaintiffs that it had selected a contractor but the project start date was undetermined. On December 9, 2024, the Forest Service gave notice that work would begin as early as that week. Id. The same day, Plaintiffs told the Forest Service that a complaint had been drafted and if the Forest Service did not agree to hold off work, Plaintiffs "anticipated filing a motion for a preliminary injunction/TRO by the end of the week." Id. According to Plaintiffs' briefing, work for the Paoli Project began on December 13, 2024. Plaintiffs initiated this action three days later, on December 16, 2024, by filing an unverified Complaint alleging violations of NEPA, violations of the Administrative Procedure Act, and a threatened violation of the Migratory Bird Treaty Act (Filing No. 1). Plaintiffs specifically allege

that the Forest Service inappropriately used a CE and either ignored or failed to inquire about the existence of extraordinary circumstances requiring an EA or environmental impact statement; made its decision prematurely and without conducting proper investigation, research, or analysis; failed to analyze the impact of the Buffalo Springs Project and Paoli Project together under NEPA; acted arbitrarily and capriciously; and threaten to negatively affect protected species of bird. On the afternoon of December 20, 2024, Plaintiffs filed the instant TRO, followed by a Motion for Preliminary Injunction. That evening, the Court issued an Order directing the parties to meet with the Magistrate Judge to discuss a discovery plan, briefing schedule, and hearing date on Plaintiffs' Motion for Preliminary Injunction (Filing No. 10). Concerning the TRO, the Court ordered Plaintiffs to file a statement identifying any action implementing the Paoli Project

occurring before Monday December 23, 2004 and December 30, 2024. Id. On December 21, 2024, Plaintiffs filed two statements in response to the Court's December 20, 2024 Order, both of which describe correspondence between counsel regarding anticipated work on the Paoli Project, as well as Plaintiffs' visual and auditory observations in the Paoli Project area (Filing No. 14; Filing No. 15). On December 20, 2024 counsel for Defendants appeared and filed the instant Motion to Convert, which asks the Court to convert the TRO to a Motion for Preliminary Injunction and allow Defendants to file a response by December 23, 2024 (Filing No.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
MAHLER v. UNITED STATES FOREST SERVICE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mahler-v-united-states-forest-service-insd-2024.