Seattle Audubon Society v. Evans
United States District Court for the Western District of Washington
771 F. Supp. 1081 (1991)
The Forest Service (defendant) repeatedly failed to adopt promised interim guidelines, comply with a congressional mandate to prepare a species-viability plan, and satisfy its National Forest Management Act obligations regarding owl habitat, while the Fish and Wildlife Service separately violated the Endangered Species Act by not designating the owl's critical habitat; Seattle Audubon (plaintiff) moved for a permanent injunction against further owl-habitat timber sales pending lawful compliance.
Whether a court may issue an injunction to compel government action under the National Forest Management Act if the government has not acted lawfully and irreparable harm would otherwise result.