Louisiana v. Haaland

The Fifth Circuit Court of Appeals ruled that four conservation groups lacked standing to appeal a preliminary injunction that ordered the Bureau of Ocean Energy Management (BOEM) to hold a specific oil and gas lease sale in the Gulf of Mexico that the Inflation Reduction Act required BOEM to hold by September 30, 2023. The State of Louisiana, the American Petroleum Institute, and two fossil fuel companies challenged BOEM’s decision to add restrictions to the terms of the lease sale to protect the endangered Rice’s whale. The Fifth Circuit found that the alleged injury to the conservation groups’ members depended on a “highly attenuated chain of possibilities” that was “insufficient to show injury in fact.” The Fifth Circuit additionally found that the groups failed to show that a favorable decision would redress the alleged injury. The Fifth Circuit ordered BOEM to conduct the sale in 37 days, which was the time BOEM said was required to provide notice of the sale in the Federal Register.

The court directed the clerk to close the case after the lease sale occurred subject to the terms laid out in the court’s preliminary injunction.