Wyoming v. U.S. Department of Agriculture

The U.S. Forest Service (defendant), acting under its broad Organic Act authority to protect national forests, issued the Roadless Area Conservation Rule barring road construction and most timber harvesting in inventoried roadless areas (IRAs) within national forests. Wyoming (plaintiff) challenged the rule, arguing it created a de facto wilderness designation without following the Wilderness Act's formal designation process. The district court agreed that wilderness areas and IRAs were essentially equivalent — since IRAs were actually more restricted in permitted uses — and permanently enjoined the rule; the Forest Service appealed.

Whether areas designated as federal wilderness under the Wilderness Act of 1964 are distinct from inventoried roadless areas located within national forests.