Southern Utah Wilderness Alliance v. Palma, 707 F.3d 1143

SUWA challenges BLM and IBLA decisions deeming 39 Kirkwood oil and gas leases suspended pending CHL conversion reviews in Circle Cliffs and Tar Sand Triangle STSAs.
Kirkwood sought CHLs under the Combined Hydrocarbon Leasing Act; three CHL applications (UTU-72405, UTU-73098, UTU-72120) included these leases and required complete plans of operations.
BLM determined complete plans were filed in 1983–1984, leading to alleged automatic suspensions; SUWA contends no suspensions were properly effected and the leases expired.
Several leases lie within or near restricted lands (e.g., Grand Staircase-Escalante National Monument), affecting possible new mineral leasing; development status remains tied to CHL outcomes.
BLM issued interim 2006–2007 decisions treating leases as suspended and imposing back rent; IBLA later reinstated some leases and remanded issues; district court dismissed for lack of standing, later amended; case proceeded to appellate review.
Court ultimately finds the action not ripe for review and remands to dismiss without prejudice due to uncertainty about future drilling rights and CHL outcomes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing viability	SUWA has injury in fact via members' use and aesthetic interests harmed by retroactive suspensions.	Lack of concrete, imminent use of the particular leases; injuries abstract or speculative.	SUWA has standing at the pleading stage.
Ripeness	Challenged suspensions directly affect lessee rights and surface use; action ripe for review.	Agency process ongoing; no final decision or immediate impact; premature.	Case not ripe; suit remanded to district court to dismiss without prejudice.

Summers v. Earth Island Inst., 555 U.S. 488 (2009) (standing injury must be concrete and particularized)
Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167 (2000) (standing requires injury in fact; organizational standing)
Defenders of Wildlife v. Lujan, 504 U.S. 555 (1992) (concept of injury in fact; particularized and concrete)
Warth v. Selden, 422 U.S. 490 (1975) (standing principles and injury requirements)
Abbott Labs. v. Gardner, 387 U.S. 136 (1967) (ripeness and finality in administrative decisions)
National Wildlife Federation v. NM ex rel. NM, 497 U.S. 871 (1990) (context on standing and use of land in environmental litigation)
Coal. for Sustainable Res., Inc. v. U.S. Forest Serv., 259 F.3d 1244 (10th Cir. 2001) (two-factor ripeness/finality framework)