## Facts

- Congress designated the Santa Teresa Wilderness in Arizona as part of the National Wilderness Preservation System in 1984.
- APHIS and the U.S. Forest Service conducted lethal control of mountain lions in the wilderness area to protect private livestock.
- A coalition of conservation organizations and an individual sued to enjoin the predator-control program.
- Plaintiffs alleged the program violated the Wilderness Act’s mandate to preserve wilderness character and natural conditions.
- Plaintiffs also alleged the agencies failed to perform adequate environmental review under NEPA before deciding to kill mountain lions.
- The district court granted summary judgment for APHIS and the Forest Service; Arizona intervened in support of the federal defendants.
- Plaintiffs appealed.

## Issues

1. Whether lethal mountain-lion control in a designated wilderness area to protect private livestock violates the Wilderness Act.
2. Whether APHIS and the Forest Service complied with NEPA’s procedural requirements, including taking a “hard look” at environmental consequences, before implementing or continuing the predator-control program.

## Decision

- The Ninth Circuit affirmed summary judgment for APHIS and the Forest Service.
- The court held the predator-control program did not violate the Wilderness Act under the governing statutory and management framework.
- The court held the agencies’ NEPA review was sufficient and not arbitrary or capricious.

## Legal Principles

- The Wilderness Act requires preservation of wilderness character but does not categorically prohibit all human management actions affecting wildlife; legality depends on statutory limits and applicable land-management decisions.
- Courts review wilderness-management choices with deference where the agency interpretation is reasonable and consistent with the statutory scheme, including preexisting authorized uses such as grazing.
- NEPA imposes procedural duties and requires a “hard look” at environmental consequences; it does not mandate particular substantive outcomes.
- Under APA arbitrary-and-capricious review, an agency’s NEPA compliance is upheld when the record shows consideration of relevant environmental factors and the challenged determination is reasonable.

## Conclusion

The Ninth Circuit allowed continued lethal mountain-lion control in the Santa Teresa Wilderness, concluding the program was permissible under the Wilderness Act’s management framework and that the agencies’ NEPA analysis satisfied the required procedural review.


Forest Guardians v. Animal & Plant Health Inspection Serv., 309 F.3d 1141 (9th Cir. 2002)