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Animal Law Keyed to Wagman
Humane Society of the United States v. Zinke
Citation:
865 F.3d 585 (2017)Facts
The gray wolf was once abundant across North America but was driven to near extinction by the 1960s. In 1978, the Fish and Wildlife Service listed gray wolves as endangered in the lower 48 states, except in Minnesota where they were listed as threatened. After several failed attempts to delist wolves in the Western Great Lakes region, the Service issued a 2011 Rule that designated wolves in Minnesota, Wisconsin, Michigan, and portions of six other states as a distinct population segment and simultaneously removed them from federal protection. The Service determined that this population was discrete, significant, and neither endangered nor threatened. The Service focused on the wolves’ current range rather than historical range in making its determination. The Humane Society challenged this decision, arguing that the Service could not designate a segment solely to delist it and that the Service failed to consider the impact of historical range loss and other threats to the wolves.
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