Reed v. Salazar

Two environmental advocacy groups challenged the decision of the U.S. Fish and Wildlife Service (FWS) to grant operational management of the National Bison Range in western Montana to the Confederated Salish and Kootenai Tribes of the Flathead Reservation. The District Court for the District of Columbia held the Service‘s decision to classify the management agreement as a categorical exclusion to environmental review violated the National Environmental Policy Act. The Court held the management agreement be set aside, effectively returning control of the National Bison Range to FWS.