Sierra Club v. Department of the Interior
376 F.Supp. 90 (N.D.Cal. 1974)
398 F.Supp. 284 (N.D.Cal. 1975)
424 F.Supp. 172 (N.D.Cal. 1976)

  • Redwood National Park was surrounded by privately-owned forest land. Timber harvesting on that private land was endangering the Park.
    • Timber harvesting just upstream of the park was polluting the water running through the park. In addition, deforestation left the Park vulnerable to high winds, landslides and siltation.
  • The Sierra Club petitioned the Department of the Interior (DOI) to take actions against the private landowners to protect the Park.
    • In response, DOI did an investigation and wrote several reports. However, they took no actions other than asking the timber companies to voluntarily change their operations.
      • Despite the fact that the reports suggested a number of actions DOI could take.
  • Sierra Club sued to force DOI to take action.
    • Sierra Club argued that the National Park System Act (16 U.S.C. 1) and the Redwood National Park Act (RNPA) (16 U.S.C. 79(a)) said that DOI has a judicially-enforceable duty to exercise their powers to prevent or mitigate damage to the Park.
    • DOI argued that they had discretion to take (or not take) actions.
  • The Trial Court found for Sierra Club.
    • The Trial Court looked to the Administrative Procedures Act (APA) and Rockbridge v. Lincoln (449 F.2d 567 (1971)), and found that DOIs actions are reviewable unless there is a clear and convincing showing that Congress intended there to be no judicial review.
    • The Court looked to RNPA 70(e) and found that it imposed a legal duty on DOI to use its powers to protect the Park.
      • The Court found that DOI had a non-discretionary, fiduciary duty to protect the Wilderness Area. They did not have the authority to allow it to be damaged.
    • The Court ordered DOI to take actions.
  • In response to the ruling, DOI continued to do some studies, and entered into cooperative agreements with some of the timber companies. Sierra Club sued again.
    • Sierra Club argued that DOI had not complied with the intent of RNPA, or its fiduciary duty to protect the Park.
    • DOI argued that their failure to act was due to a lack of scientific data, a lack of funds, and that the cooperative agreements were sufficient.
  • The Trial Court found for Sierra Club.
    • The Trial Court found that DOI had not taken steps to implement most of the recommendations in their reports.
    • The Court found that the cooperative agreements were insufficient.
    • The Court ordered DOI to take reasonable steps to protect the Park, exercising the powers vested in them by RNPA. In addition, DOI was ordered to prepare a report outlining what progress they've made.
  • DOI went back and tried a number of things to protect the park, but they all failed. Sierra Club sued again.
    • DOI asked the Office of Management and Budget for additional authority but were rebuffed.
    • DOI asked the timber companies to comply with more voluntary guidelines, but they declined.
    • DOI asked the governor of California for money but were refused.
    • DOI asked the Department of Justice (DOJ) to commence litigation against the timber companies, but DOJ did not act.
  • The Trial Court found that DOI had made a good faith effort to protect the park.
    • The Trial Court suggested that the only thing that could be done was Congressional action.
    • Congress actually responded by enacting the Redwood Park Expansion Act (92 Stat. 163), which expanded the Park.