## Facts

- The U.S. Forest Service adopted a Land and Resource Management Plan for the Wayne National Forest under the National Forest Management Act of 1976 (NFMA).
- The Plan identified areas suitable for timber production, set logging goals, and capped projected harvest levels over a ten-year period.
- The Plan did not itself authorize tree cutting; any logging required later, site-specific proposals and approvals.
- Before approving a timber sale, the Forest Service had to propose a specific site and harvest method, ensure plan consistency, provide public notice and an opportunity to be heard, conduct environmental review, and issue a final decision subject to administrative and judicial challenge.
- Sierra Club and another organization challenged the Plan, alleging it allowed excessive logging and clearcutting in violation of NFMA.

## Issues

1. Whether a challenge to a forest management plan that sets goals and designations but does not authorize site-specific logging is ripe for judicial review.
2. Whether withholding immediate review would impose sufficient hardship to justify pre-implementation adjudication.

## Decision

- The Supreme Court unanimously held the dispute was not justiciable because it was not ripe for judicial review.
- The Court reversed the Sixth Circuit, which had found the challenge ripe and ruled the Plan violated NFMA.
- The Court did not reach the merits of whether the Plan complied with NFMA.

## Legal Principles

- Ripeness turns on (1) the fitness of the issues for judicial decision and (2) the hardship to the parties of withholding review.
- A planning-level agency document is generally unripe for review when it does not itself authorize on-the-ground action and has no direct, immediate legal consequences.
- No sufficient hardship exists where the challenged plan imposes no present legal obligations, grants no present legal rights to act, and does not require immediate changes in the challenger’s conduct to avoid sanctions.
- Claims are more fit for review when tied to later, site-specific implementation decisions that concretely define location, methods, mitigation, and environmental effects, and that remain open to administrative and judicial challenge.

## Conclusion

Because the forest plan guided future management but did not itself permit logging or alter the parties’ legal rights and duties, and because affected parties could challenge later site-specific logging decisions when harm became imminent and certain, the pre-implementation suit was unripe.


Ohio Forestry Ass'n, Inc. v. Sierra Club, 523 U.S. 726 (1998)