West Virginia Div. of Izaak Walton League of America, Inc. v. Butz

The Forest Service (defendant) entered timber-sale contracts in the Monongahela National Forest covering trees that were neither dead, physiologically mature, nor large, and that were never individually marked before cutting, relying on the Organic Act's authorization to sell dead, matured, or large growth of trees; the Izaak Walton League (plaintiff) sued, and the district court enjoined the sales as violating the Act, prompting the Forest Service's appeal, which argued large growth referred to tree quantity and mature could mean economic or management maturity rather than physiological maturity.

Whether the Organic Act of 1897 authorizes the sale of national-forest trees only if the trees are physiologically mature and individually marked and designated before sale.