## Facts

- Congress enacted the Redwood National Park Act (1968) to preserve coastal redwood forests and authorized the Secretary of the Interior to acquire nearby lands, adjust park boundaries, and use enforceable agreements to prevent damage to park resources.
- Logging on private lands adjacent to portions of Redwood National Park caused and threatened damage to park resources, including impacts to streams and ecological systems.
- Interior, through agency studies beginning in 1969, documented ongoing and foreseeable harm and recommended protective measures such as land acquisition, easements/management zones, protection of stream corridors, and streamside logging restrictions or moratoria.
- The Secretary largely did not implement the recommended measures; instead, Interior relied primarily on “cooperative agreements” with timber companies and continued studying conditions while logging continued.
- Sierra Club, a conservation organization with members who used the park for hiking, camping, and photography, sued seeking declaratory and mandatory relief for failure to protect the park from adjacent logging impacts.
- After an earlier ruling recognizing potentially enforceable statutory and fiduciary duties, the court conducted a trial on the merits and issued findings and conclusions.

## Issues

1. Whether Sierra Club had standing based on injury to its members’ aesthetic, conservational, and recreational interests from damage to Redwood National Park.
2. Whether the Secretary’s failure to implement effective protective measures against known, ongoing logging-related harm violated statutory and fiduciary duties and amounted to arbitrary or unreasonable agency inaction.
3. Whether declaratory relief and a mandatory injunction were appropriate to compel protective action.

## Decision

- The court held Sierra Club had standing because its members’ use and enjoyment of the park were harmed by damage to park resources.
- The court found the Secretary owed statutory and fiduciary duties to protect Redwood National Park from preventable harm, including harm originating on adjacent private lands.
- The court concluded the Secretary acted unreasonably, arbitrarily, and in abuse of discretion by failing to take necessary protective measures despite documented harm and specific agency recommendations.
- The court granted declaratory and mandatory relief directing the Secretary to act consistently with those duties.

## Legal Principles

- An organization has standing when its members suffer injury in fact to aesthetic, recreational, and conservational interests from environmental damage affecting their use and enjoyment of public lands.
- The Secretary of the Interior has affirmative duties, grounded in both statutory authority and trust-like obligations for national parks, to protect park resources from known and preventable damage.
- When an agency has documented ongoing harm and possesses feasible statutory tools to address it, prolonged reliance on nonbinding or ineffective measures and continued inaction may constitute arbitrary action or an abuse of discretion warranting mandatory injunctive relief.
- Agency discretion does not extend to abdication of legally imposed protective responsibilities for park resources.

## Conclusion

The court held that Sierra Club could sue to protect its members’ use of Redwood National Park and that Interior’s prolonged failure to implement effective protections against documented logging-related harm violated the Secretary’s statutory and fiduciary obligations, justifying declaratory and mandatory injunctive relief.


Sierra Club v. Dep’t of the Interior, 398 F. Supp. 284 (N.D. Cal. 1975)