Civil Action No. 2017-2590
D.D.C.Nov 25, 2024Background
- Plaintiffs challenge former President Donald J. Trump’s 2017 proclamation significantly reducing the size of Bears Ears National Monument, alleging violations of the Antiquities Act, the U.S. Constitution, and the Administrative Procedure Act.
- The cases were consolidated and later stayed while the Biden administration reviewed and ultimately reversed the Trump Proclamation, restoring the Bears Ears Monument boundaries.
- The State of Utah (an Intervenor-Defendant) brought a separate challenge to the Biden Proclamation, which was dismissed by the District of Utah; Utah’s appeal is pending before the Tenth Circuit.
- Intervenor-Defendants moved to lift the stay in the consolidated D.C. case to allow them to seek dismissal based on mootness; Plaintiffs and federal defendants argued to continue the stay until the Tenth Circuit appeal resolves.
- The D.C. court considered judicial economy and hardship to the parties, both in terms of resources and potential prejudice.
- The court has required parties to file joint status reports and will revisit proceedings after the Tenth Circuit ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to lift the stay and reopen the case | Maintain stay pending Tenth Circuit appeal to avoid duplicative or unnecessary proceedings | Lift stay and dismiss case as mooted by Biden Proclamation | Stay maintained pending Tenth Circuit, as it conserves resources and no hardship was shown by defendants |
| Whether the court must act due to changed circumstances after Biden restored Bears Ears | Issues are not resolved since Tenth Circuit outcome may affect scope and claims | Changed circumstances (Biden Proclamation) justify dismissal now | Pending appeal is likely to clarify or resolve issues, so continuing the stay is appropriate |
| Potential prejudice or hardship from continuing stay | No concrete harm to Intervenor-Defendants | Theoretical risk of unfavorable settlement or delay | No cognizable hardship from stay; possible settlement is speculative and not connected to the stay |
| Proper course of proceedings | Wait for outcome in the Tenth Circuit | Proceed now in D.C. District Court | Efficient to wait for appellate ruling; parties must file joint status post-Tenth Circuit |
Key Cases Cited
- Landis v. N. Am. Co., 299 U.S. 248 (discusses court’s inherent authority to stay proceedings and balance judicial economy against hardship)
- Bledsoe v. Crowley, 849 F.2d 639 (circuit precedent on a court’s discretion to stay proceedings)