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Court: Expanded livestock grazing in grizzly habitat near Yellowstone violated law

For immediate release

September 17, 2025

Contacts:

Court: Expanded livestock grazing in grizzly habitat near Yellowstone violated law

MISSOULA, Mont. – Today, The U.S. District Court for the District of Montana found that the U.S. Forest Service violated the law when it authorized expanded livestock grazing on six allotments on the east side of Montana’s Paradise Valley in occupied grizzly bear habitat. The allotments lie just north of Yellowstone National Park in the Absaroka Mountains.

The court found that the Forest Service failed to analyze the effects of authorizing expanded livestock grazing on public lands in the area—specifically, allowing more grazing in more areas and a longer grazing season. The agency failed to properly analyze the effects of early stocking dates, failed to analyze how expanded grazing may affect grizzly bear connectivity in the area—an important factor for grizzly bear recovery—failed to analyze the cumulative effects of this expanded grazing in combination with other activities on private lands, and failed to prepare an environmental impact statement as required by the National Environmental Policy Act. The court remanded the matter back to the Forest Service to prepare a new analysis and vacated the agency’s decision to expand grazing on these allotments, thus preserving the status quo, which is more favorable to grizzly bears.

Several of the allotments are in designated grizzly recovery zones and within important habitat linkages for bears in the Absaroka-Beartooth Wilderness. The Forest Service had expanded both the livestock grazing area and season, which the best science reveals will put grizzly bears at higher risk of being killed in response to conflict with cattle operations. Increased grizzly bear mortality in areas on the outskirts of the Greater Yellowstone Ecosystem would slow the bears’ recovery and keep the Yellowstone grizzly population isolated. Scientists predict that long-term isolation of Yellowstone grizzlies will likely decrease their genetic diversity, which would harm the population’s health and reproductive success.

“The best available science says steps need to be taken to help facilitate grizzly bear movement and connectivity between subpopulations to fully recover the species in the lower 48 states,” said Matthew Bishop, senior attorney at the Western Environmental Law Center representing the groups. “We agree the agency needs to take a harder, closer look at these issues before authorizing activities in important linkage areas like the Absaroka Range.” 

“Despite knowing that livestock conflict remains a leading cause of death for grizzly bears in the Greater Yellowstone Ecosystem, the Forest Service sought to expand cattle grazing on public lands surrounding the National Park,” said Patrick Kelly, Montana director with Western Watersheds Project. “Judge Molloy’s decision has thankfully halted this misguided and illegal effort, likely preventing the deaths of many more grizzly bears.”

In recent decades, Yellowstone grizzly bears have also experienced a drastic decline in two of their main food sources: whitebark pine nuts and Yellowstone cutthroat trout. This has led them to consume more meat, which sometimes includes livestock, especially when cattle are permitted to graze in backcountry areas.

“I’m thrilled the court struck down the federal government’s illegal decision to increase livestock grazing in important grizzly bear habitat,” said Andrea Zaccardi, carnivore conservation legal director at the Center for Biological Diversity. “Putting livestock on public lands where grizzlies live is akin to baiting these bears into conflicts. I hope the Forest Service will revisit its decision and decide not to move forward with this irresponsible proposal.”

“There should never be a wildlife resource policy whereby domestic livestock have priority over wildlife on public lands, yet that is essentially what was done in this case”, said Clint Nagel, president of the Gallatin Wildlife Association. “The underlying premise that wildlife is expendable, that they will always be present in our world, has simply been proven wrong. We should know by now, that is not and will not be the case.”

“The science is clear: grizzly bears need safe, livestock-free passage between population cores in order to fully recover,” said Lizzy Pennock, carnivore coexistence attorney at WildEarth Guardians. “We are grateful the judge redirected the U.S. Forest Service toward the best available science and its legal responsibility to protect wildlife.”

“Montana’s Paradise Valley is aptly named,” said Mike Garrity, executive director for the Alliance for the Wild Rockies. “Sitting between two towering mountain ranges, it cradles the mighty Yellowstone River that flows from its headwaters in America’s first national park and provides critical habitat to the native species still present 200 years after Lewis and Clark’s expedition. Yet, the Forest Service decided to expand cattle grazing on six allotments on the valley’s east side, including in a grizzly bear ‘recovery zone.’ It was a formula for the destruction of native vegetation, sedimentation in cutthroat spawning streams, and for dead wolves and bears.”

“The Forest Service based its analysis on the 1998 baseline population data when there were few grizzly bears north of Yellowstone National Park and before climate change greatly diminished whitebark pines, the nuts of which have historically been the grizzlies’ primary food source,” said Dr. Sara Johnson, Ph.D., director of Native Ecosystems Council and retired Custer National Forest wildlife biologist. “Illegally introduced lake trout likewise slashed Yellowstone’s once abundant native cutthroat trout, which provided a high-protein food source for the bears but today are threatened with extinction. A quarter century later, it’s simply a fact that there are many grizzlies living in the Montana portion of the Greater Yellowstone Ecosystem, including in the vast Absaroka-Beartooth Wilderness Area, where some of the grazing allotments are located. It is imperative that the Forest Service analyze the impact of the grazing decision on the current conditions grizzlies bears face today.”

“Allowing more livestock grazing in prime grizzly bear habitat would have been irresponsible and threatens long-term recovery of grizzly bears in the Yellowstone ecosystem,” said Nick Gevock, campaign organizer for the Sierra Club. “The Forest Service’s decision was misguided, considering the number of grizzly bears that are already killed every year as a result of conflicts with livestock operations in the Yellowstone region. Bears need to be able to move through this landscape and connect with grizzly bears to the north to ensure long-term recovery.”

“Greater Yellowstone Ecosystem grizzly bears will never be able to connect with other bear populations if we continue to allow increased cattle grazing in prime habitat like the Paradise Valley,” said Kristin Combs, executive director for Wyoming Wildlife Advocates. “Until livestock producers use conflict deterrents instead of lethal force against bears, grazing will continue to lead to dead bears.”

The groups’ original complaint is available here.

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