Northern Alaska Environmental Center v. Trump

This was a Rule 12(b)(1) standing exit, not a merits verdict on EO 14148; the constitutional question reached the courthouse door and was asked for ID it did not have. OCSLA §12(a) lets a President withdraw unleased OCS lands; it does not, in text, issue an un-withdrawal key. The timeline is a relay race where the baton is litigation: Obama withdrew Arctic/Atlantic acreage in 2015–16; Trump’s EO 13795 purported to revoke that in 2017; Biden’s EO 13990 revoked the revocation in 2021, then added Beaufort protections in 2023 and broader Pacific/Atlantic/Gulf/Bering withdrawals in January 2025; Trump’s EO 14148 purported to rescind Biden’s on Jan. 20. Three presidents, four reversals, zero merits answers. Plaintiffs alleged a Property Clause violation and that the rescission was ultra vires under OCSLA, but future injury must be certainly impending or carry substantial risk. Because DOJ made a factual attack, the complaint got no presumption-of-truth pillow. The anvil was BOEM’s Carr declaration: pending G&G applications exist only in the Western/Central Gulf; none off Alaska, the Pacific, the Atlantic, or the Eastern Gulf. League of Conservation Voters had an actual seismic operator seeking actual permits and only a facial attack. Mothers for Peace had a plant already aging past its license; this is South Carolina’s chain of maybes. Dismissed without prejudice: come back when a lease sale stops being a vibe.