National Park Conservation Association v. U.S. Department of the Interior

No. 26-1714 · United States Court of Appeals for the First Circuit · June 23, 2026 · No. 26-1714

Summary

The United States Court of Appeals for the First Circuit partially grants the defendants' request for an immediate administrative stay pending appeal. The stay applies to paragraphs 2, 3, and 4 of the district court's preliminary-injunction order, while leaving in place the district court's stay of the Secretary's order under 5 U.S.C. § 705. The court states that it will promptly rule on the request for a stay pending appeal.

Court
United States Court of Appeals for the First Circuit
Writing for the Court
David J. Barron, Chief Judge; Gustavo A. Gelpí, Circuit Judge; Ketanji Brown Jackson Rikelman, Circuit Judge
Jurisdiction
United States Court of Appeals for the First Circuit
Decision date
June 23, 2026
Docket number
26-1714
Procedural posture
Interlocutory appeal from a preliminary injunction and defendants-appellants' emergency motion for an administrative stay pending appeal.
Standard of review
The court conducted a careful review of the emergency motion and opposition; the order does not articulate a separate standard of review.
Precedential value
Unknown
Parties
U.S. Department of the Interior, Doug Burgum, in the official capacity as Secretary of the Interior, National Park Service, Jessica Bowron, in the official capacity as the Official Exercising the Delegated Authority of the Director v. National Park Conservation Association, American Association for State and Local History, Association of National Park Rangers, Coalition to Protect America's National Parks, Society for Experiential Graphic Design, Union of Concerned Scientists
Disposition
other

Topics

interlocutory appealappellate procedureadministrative lawjudicial review of agency actionnational parks

Practice areas

Administrative lawAppellate procedureNational parks

Questions Presented

  1. Whether the First Circuit should grant an immediate administrative stay of portions of the district court's preliminary injunction pending consideration of the defendants' motion for a stay pending appeal.

Holdings

  1. The First Circuit granted the request for an administrative stay in part, immediately staying paragraphs 2, 3, and 4 of the district court's order while leaving in place the district court's stay of the Secretary's order under 5 U.S.C. § 705.

Key quotations

That is, the request for an immediate administrative stay of paragraphs 2, 3, and 4 of the Order is granted.
This administrative stay leaves in place the District Court's stay of the Secretary's Order under 5 U.S.C. § 705.

Factual background

The district court entered a preliminary injunction concerning the Secretary's order, including a stay under 5 U.S.C. § 705. The defendants sought immediate appellate relief, while the plaintiffs opposed the motion.

Procedural history

The District Court for the District of Massachusetts entered a preliminary injunction on June 12, 2026, including paragraphs 2, 3, and 4 and a stay of the Secretary's order under 5 U.S.C. § 705. Defendants appealed and sought an emergency stay pending appeal or, alternatively, an administrative stay. The First Circuit addressed only the administrative-stay request in this order.

Court Document

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