Wilderness Workshop v. Boren

Wilderness Workshop · United States District Court for the District of Columbia · February 24, 2026 · No. Civil Action No. 2023-0678; 23-cv-678 (JMC)

Summary

The court holds that section 3210(a) of the Alaska National Interest Lands Conservation Act applies nationwide to nonfederally owned land within the boundaries of the National Forest System, rather than only to land in Alaska. It grants partial summary judgment to the Government and intervenor Berlaimont Estates and denies the environmental organizations’ motion on that issue. The court also concludes that Wilderness Workshop has associational standing.

Holdings

  1. Section 3210(a) applies to nonfederally owned land within the boundaries of the National Forest System throughout the United States, not only in Alaska.
  2. Wilderness Workshop demonstrated associational standing to pursue the challenged claim.
  3. Defendants haled into federal court need not establish standing merely to defend themselves or seek judgment on the plaintiffs' claim.

Questions Presented

  1. Whether section 3210(a) of the Alaska National Interest Lands Conservation Act applies to nonfederally owned land within the boundaries of the National Forest System throughout the United States or only in Alaska.
  2. Whether Wilderness Workshop sufficiently established associational standing to challenge the Forest Service's approval.
  3. Whether the Government and intervenor-defendant were required to establish standing before defending against the plaintiffs' claims or seeking judgment in their favor.

Disposition

other

Cases Cited (25)

  • Wilderness Workshop v. Harrell, 676 F. Supp. 3d 1, 3 (D.D.C. 2023)(followed)
  • Gilbert v. Wilson, 292 F. Supp. 3d 426, 433 (D.D.C. 2018)(followed)
  • Summers v. Earth Island Inst., 555 U.S. 488, 499 (2009)(followed)
  • Biden v. Nebraska, 600 U.S. 477, 489 (2023)(followed)
  • Ctr. for Sustainable Econ. v. Jewell, 779 F.3d 588, 596-98 (D.C. Cir. 2015)(followed)
  • Lujan v. Defs. of Wildlife, 504 U.S. 555, 562-64 (1992)(followed)
  • Animal Legal Def. Fund, Inc. v. Glickman, 154 F.3d 426, 440 (D.C. Cir. 1998)(followed)
  • Sugar Cane Growers Co-op. of Fla. v. Veneman, 289 F.3d 89, 94-95 (D.C. Cir. 2002)(followed)
  • TransUnion LLC v. Ramirez, 594 U.S. 413, 430-31 (2021)(followed)
  • Nat'l Parks Conservation Ass'n v. United States, 177 F. Supp. 3d 1, 16 n.6 (D.D.C. 2016)(followed)

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