In Defense of Animals v. United States Department of the Interior, 648 F.3d 1012

Interlocutory appeal from district court order denying a TRO/preliminary injunction to halt a roundup of Twin Peaks wild horses and burros.
Plaintiffs sought to preserve the status quo by enjoining the roundup of over 2,000 horses and 200 burros.
Defendants relied on the Wild Free-Roaming Horses and Burros Act and NEPA.
Roundup occurred before appeal decision; horses are offsite and remaining plan proceeds.
Court dismisses the appeal as moot regarding the injunction, while noting the merits remain pending.
Dissent argues NEPA relief is not moot and relief could still be provided by returning horses to habitat.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the interlocutory appeal moot after roundup completion?	Plaintiffs contend mootness should not bar review of the injunction denial.	Defendants claim the relief sought is rendered moot by completion of the roundup.	Yes, the appeal is moot as to the injunction relief.
Is NEPA relief still available despite mootness of the injunction?	Relief remains possible by returning horses to habitat; not moot.	Once roundup completed, the action cannot undo effects.	No, NEPA relief moot only if no effective relief remains.

Animal Legal Defense Fund v. Shalala, 53 F.3d 363 (D.C. Cir. 1995) (underlying dispute remains alive after denial of injunction when relief is possible)
Friends of the Earth, Inc. v. Bergland, 576 F.2d 1377 (9th Cir. 1978) (mootness evaluated by whether effective relief can be granted)
Northwest Environmental Defense Ctr. v. Gordon, 849 F.2d 1241 (9th Cir. 1988) (relief available where restoration can occur; not moot if relief feasible)
Am. Horse Prot. Ass'n, Inc. v. Watt, 679 F.2d 150 (9th Cir. 1982) (court cannot undo completed roundup; mootness analysis on posture of action)