## Facts

- Redwood National Park was created to preserve primeval redwood forest, but adjacent private timberlands upstream and uphill remained outside park boundaries and were subject to intensive logging.
- Sierra Club alleged that logging practices on those private lands caused erosion, landslides, flooding, and sedimentation that damaged park resources, including timber, soil, and streams.
- Sierra Club requested that the Secretary of the Interior use statutory tools under the Redwood National Park Act and related authority (e.g., acquisition of interests, protective agreements) to mitigate or prevent the harms.
- The Secretary largely sought voluntary cooperation from logging companies and did not take additional measures that Sierra Club viewed as necessary.
- Sierra Club sued for declaratory and mandatory relief requiring the Secretary to act to protect park resources.
- The government moved to dismiss and for summary judgment, arguing lack of standing, nonreviewable agency discretion, and absence of any enforceable duty to take the demanded measures.

## Issues

1. Whether Sierra Club had standing based on its members’ aesthetic, recreational, and conservational use of the park allegedly harmed by the Secretary’s inaction.
2. Whether the Redwood National Park Act, read with the National Park Service Organic Act, imposes enforceable statutory and fiduciary-like duties on the Secretary to protect park resources from foreseeable external harms.
3. Whether claims challenging the Secretary’s alleged failure to employ available statutory tools are judicially reviewable or committed to agency discretion.
4. Whether the amended complaint alleged facts that, if proven, could warrant declaratory and mandatory relief.

## Decision

- The court held that Sierra Club had standing to sue on behalf of members who use and enjoy Redwood National Park and whose interests were allegedly injured by degradation of park resources.
- The court held that the Secretary has statutory and fiduciary-like duties concerning protection of Redwood National Park resources under the governing park statutes.
- The court found the dispute justiciable and the claims judicially reviewable where plaintiffs alleged unlawful failure to carry out statutory conservation responsibilities.
- The court denied the government’s motion to dismiss and motion for summary judgment, concluding the amended complaint alleged facts that, if established, could support declaratory and mandatory relief.

## Legal Principles

- An organization may establish standing by alleging concrete injury to members’ aesthetic, recreational, or conservational interests from harm to a national park they use and enjoy.
- Statutory conservation mandates governing national parks can impose affirmative, enforceable obligations on the Secretary of the Interior to protect park resources from foreseeable damage, including damage originating outside park boundaries.
- Agency inaction is subject to judicial review when plaintiffs plausibly allege that the agency failed to carry out duties imposed by statute, even if implementation involves policy choices.
- At the pleading and dispositive-motion stage, allegations that park resources are being harmed and that the Secretary has not used available statutory mechanisms to provide protection can be sufficient to proceed toward declaratory and mandatory relief.

## Conclusion

The court permitted Sierra Club’s suit to proceed by recognizing member-based standing, treating federal park management duties as enforceable under the relevant statutes, and holding that alleged failure to protect Redwood National Park from adjacent logging impacts could be reviewed and, if proven, remedied through declaratory and mandatory relief.


Sierra Club v. Dep’t of the Interior, 376 F. Supp. 90 (N.D. Cal. 1974)