The US Court of Appeals for the District of Columbia on Friday [official website] ruled [opinion] in favor of the Secretary of the Interior [official website] in its efforts to remove the gray wolf from the endangered species list. Once nearly extinct, the gray wolf population has made a recovery such that it no longer meets the requirement to be considered endangered in Wyoming. The Secretary, with promises from Wyoming to maintain at least 10 breeding pairs and 100 total gray wolves in the state, sought to remove the animal from the list. Conservation groups challenged the adequacy of Wyoming’s management plan and, in particular, the danger that hunting could reduce the wolf population below Wyoming’s required minimum. The lower federal court agreed, finding that Wyoming’s promise to maintain populations was unenforceable and therefore inadequate. A three-judge appeal panel of the DC Circuit disagreed, finding that Wyoming’s guarantees are sufficient and that there is significant value in putting control of the wolf population in the hands of the state.

Gray wolves were first delisted by order of the Department of the Interior in 2011. That order applied to Montana and Idaho, but maintained federal control of wolf populations in Wyoming. Montana began selling wolf hunting licenses on the same day as the Secretary’s ruling. Before those licenses went into effect, three environmental groups challenged the hunt [JURIST report] in district court. The Ninth Circuit upheld [JURIST report] the district court’s ruling in favor of Montana. Last year, the Michigan Court of Appeals ruled [JURIST report] that a 2014 Michigan law that gave the Michigan Natural Resources Commission and State Legislature the ability to name new game animals was unconstitutional. The Michigan Constitution contains a Title-Object Clause, which states “[n]o law shall embrace more than one object, which shall be expressed in its title.” The court ruled that the portion of the wolf hunt law allowing free hunting licenses for members of the military is unrelated to the law’s purpose of managing game, which means the entire law must be struck down as violating the Title-Object Clause.