Robertson v. Seattle Audubon Society (1992)
Facts: An environmental group sued the US Forest Service, alleging that its management of old-growth forests in the Pacific Northwest violated provisions of 5 Fed environmental laws. While the lawsuit was pending, Congress enacted a law imposing requirements on the Forest Service more lenient than those imposed by the pre-existing statutes. Most importantly, the new statute “determined and directed” that compliance with those new requirements was “adequate consideration for the purpose of meeting the statutory requirements that are the basis of” pending lawsuits.
The court upheld the statute against a Klein challenge, finding it to be simply a run-of-the-mill statutory amendment.
Thus, Seattle Audobon makes clear that, at least for statutory claims (where Congress can rewrite the substantive law), Congress can in fact micromanage courts’ application of law.
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