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In American Wild Horse Campaign v. Bernhardt, No. CV 18-1529 (BAH), 2020 WL 736772 (D. D.C. Feb. 13, 2020) the court considered a challenge by environmental groups to a land use plan issued by the Bureau of Land Management (BLM) in 2008. The land use plan was for an area of public lands in Nevada known as the “Caliente Complex,” and it determined that the area would not be managed to include wild horses. In compliance with the plan, BLM engaged in an effort to round-up and relocate the wild horses present on the Caliente Complex in 2009. Despite their efforts in 2009, there are currently an estimated 1,744 wild horses found on the Caliente Complex. That prompted BLM to determine in 2018 that additional efforts to remove the horses were necessary. The plaintiffs brought this lawsuit against BLM alleging that new efforts to remove wild horses from the Caliente Complex were a violation of both the Wild Free-Roaming Horses and Burros Act (“WHBA”) and the National Environmental Policy Act (“NEPA”). However, the plaintiffs never challenged the 2008 land use plan or the 2009 wild horse removal activity. The defendants filed a motion to dismiss, and the court ruled in their favor, dismissing all of the plaintiffs’ claims. According to the court, BLM fully complied with both WHBA and NEPA in its 2018 decision to remove wild horses from the Caliente Complex. Additionally, the court concluded that because the 2018 decision was made pursuant to the 2008 land use plan, the correct action for the plaintiffs to have taken was a challenge of the land use plan, however the court also concluded that the time to challenge that plan had passed.