Cottonwood Environmental Law Center v. United States Forest Service

Overturning thirty-year-old precedent, Cottonwood Environmental Law Center v. United States Forest Service held that merely proving a procedural violation of the ESA is no longer enough to show irreparable injury in support of injunctive relief. The Ninth Circuit affirmed summary judgment for Cottonwood, concluding the Forest Service violated the ESA by not reinitiating consultation, but declined to provide injunctive relief because Cottonwood failed to show irreparable injury to the Canadian lynx.