Sierra Club v. Marita

The Forest Service (defendant) developed management plans for two Wisconsin national forests using management indicator species (MIS) and population-viability analyses rather than the conservation-biology approach — emphasizing large habitat preservation for biological diversity — that the Sierra Club (plaintiff) had urged, justifying its choice on the ground that conservation biology remained untested specifically in Wisconsin forests; Sierra Club sued, arguing the National Forest Management Act (NFMA) required an ecological, conservation-biology-based approach, that MIS analysis inadequately measured diversity, that NFMA regulations required maintaining old-growth forest communities, and that rejecting well-respected conservation biology was improper. The district court granted the Forest Service summary judgment, and Sierra Club appealed.