The D.C. Circuit Court of Appeals issued a decision February 20, 2026, in *Friends of Animals v. United States Bureau of Land Management*, a case examining the federal government's authority to manage wild horse populations on public lands through long-term planning strategies.
Friends of Animals appealed a district court ruling regarding the Bureau of Land Management's implementation of ten-year management plans designed to control wild horse populations across four geographic areas. The case centered on whether BLM's approach to gathering and removing horses complies with federal wildlife protection statutes.
The dispute arose from BLM's issuance of comprehensive ten-year plans authorizing the agency to gather and remove wild horses from designated public lands over extended periods. These management strategies represent BLM's approach to addressing what the agency views as overpopulation issues that threaten the long-term sustainability of wild horse herds.
The Wild Free-Roaming Horses and Burros Act, codified at 16 U.S.C. §§ 1331-1340, serves as the primary federal legislation governing wild horse protection and management. The statute both authorizes and directs BLM "to protect and manage wild free-roaming horses and burros as components of the public lands." This dual mandate requires the agency to balance protection of these animals with active population management.
Under the Act, BLM bears responsibility for culling wild horse populations on public lands to promote their long-term sustainability. However, the agency must adhere to specific statutory requirements designed to ensure wild horse protection during these management activities. The tension between protection and population control forms the core legal challenge in cases like this one.
Friends of Animals filed the original lawsuit in August 2018 in the U.S. District Court for the District of Columbia, challenging BLM's ten-year planning approach under the Administrative Procedure Act. The animal rights organization argued that BLM's long-term removal plans violated federal requirements for wild horse protection.
The case proceeded through the district court, where BLM defended its management authority and planning methodology. The State of Utah joined the case as an appellee, reflecting state interests in federal land management decisions within their borders.
During oral arguments held October 1, 2025, the appeals court heard from Jennifer Best, who argued for Friends of Animals alongside co-counsel Stephen Hernick. The federal government was represented by Department of Justice Attorney Ezekiel A. Peterson, working with Acting Assistant Attorney General Adam R.F. Gustafson and Attorney Robert Lundman.
Utah's interests were argued by Assistant Solicitor General Steve Geary from the state Attorney General's office, supported by Attorney General Derek Brown and Solicitor General Stanford Purser on the brief.
The three-judge panel included Circuit Judges Katsas and Childs, along with Senior Circuit Judge Edwards, who authored the court's opinion. The composition reflects the D.C. Circuit's role in reviewing federal agency actions and environmental law disputes.
The court's decision addressed fundamental questions about federal wildlife management authority and the scope of agency discretion in implementing long-term conservation strategies. The case illustrates ongoing tensions between animal rights advocates and federal land managers over appropriate methods for controlling wildlife populations.
Wild horse management represents a complex challenge for BLM, which must balance competing interests including animal welfare, ecological sustainability, ranching concerns, and public land access. The agency's ten-year planning approach reflects an attempt to provide predictable, science-based management while meeting statutory protection requirements.
The D.C. Circuit's jurisdiction over this case stems from its role as the primary venue for challenging federal agency actions. The court frequently addresses disputes involving environmental regulations, land management policies, and administrative law questions.
This decision adds to the body of precedent governing federal wildlife management authority under the Wild Free-Roaming Horses and Burros Act. The ruling will likely influence how BLM approaches future wild horse management planning and how courts evaluate challenges to federal wildlife policies.
The case demonstrates the ongoing legal complexity surrounding federal wildlife management, where agencies must navigate detailed statutory requirements while addressing practical conservation challenges. The outcome affects not only wild horse populations but also broader questions about federal land management authority and environmental protection enforcement.
The decision resolves a dispute that originated in 2018, reflecting the extended timeline often required for complex environmental litigation. The case's progression through federal courts illustrates the detailed legal review applied to federal agency wildlife management decisions.