Center for Biological Diversity v. Bureau of Land Management

The Bureau of Land Management (BLM, defendant) prepared an environmental assessment projecting only a single exploratory well for an oil and gas lease sale, without discussing fracking despite acknowledging its increasing use, and issued four leases (only two with No Surface Occupancy stipulations preventing surface disturbance without BLM authorization) after finding no significant environmental impact, without preparing a full environmental impact statement. The Center for Biological Diversity and other groups (plaintiffs) sued, arguing the BLM violated NEPA by failing to adequately analyze fracking's foreseeable impacts and violated the Mineral Leasing Act by not requiring specific waste-minimization measures; both sides moved for summary judgment.