Lawsuit filed over Callaghan Complex plan
The complaint, brought by Wild Horse Education (WHE), its founder and president Laura Leigh, and NEPA Program Coordinator and volunteer Tammi Adams, seeks injunctive and declaratory relief to stop BLM from implementing the Callaghan Complex HMAP/Gather Plan adopted on February 13, 2026. The plan covers the Callaghan, South Shoshone, Bald Mountain, and Hickison (north of U.S. Route 50) Herd Management Areas (HMAs), as well as the North Shoshone Herd Area, where BLM intends to permanently remove roughly 2,000 wild horses beginning as early as July 10, 2026. The plan targets over 5,000.
Core legal claims
The complaint alleges that BLM’s decision violates the Wild Free-Roaming Horses and Burros Act, the National Environmental Policy Act (NEPA), the Federal Land Policy and Management Act, and the Administrative Procedure Act. According to the filing, BLM relied on nearly 40‑year‑old “appropriate management levels” (AMLs) drawn from the 1986–87 Shoshone‑Eureka Resource Management Plan—still the oldest fully-operational land use plan in the country—which allocated 95.3 percent of permitted forage to livestock and just 4.7 percent to wild horses as the target goal of “management.”
“Nearly everything else on this landscape has more modern, site‑specific planning that updated that old Shoshone‑Eureka plan—mining, livestock, even sage‑grouse—but wild horses are still stuck in an RMP written the same year as the Chernobyl disaster,” said Laura Leigh, President of Wild Horse Education, “The handbook governing rangeland health has been updated twice since then, and BLM’s inventory methods for wild horses have changed, but nothing for wild horses has. Our wild horses still have no real, site‑specific management, even though someone typed it into the title of this so‑called HMAP. BLM is simply inventing new ways to avoid doing fair, transparent, data-based planning for wild horses.”
Failure to follow HMAP and NEPA requirements
WHE’s lawsuit charges that Nevada BLM is using a generic HMAP template that ignores the agency’s own Wild Horse and Burro Management Handbook requirements for site‑specific herd and habitat objectives, SMART monitoring standards, and transparent public analysis. It also ignores a 2024 court order in Leigh et. al. v Raby that states a “HMAP must be prepared,” not that the HMAP analysis can be shoved into an Appendix where the work is kicked down a vaguely defined path.
The complaint further asserts that BLM folded the HMAP into a short Environmental Assessment focused on roundups and fertility control, skipped considering an Environmental Impact Statement, and failed to establish basic environmental baselines such as water inventories, land health evaluations, or genetic and wildfire impacts.
“BLM is trying to rush a massive summer roundup under a thin Environmental Assessment that never grappled with baseline data, water, wildfire, or real carrying capacity,” said Tammi Adams, WHE’s NEPA Program Coordinator and a named plaintiff in the case. “They want to clear the range of horses now and figure out the details later—that is the opposite of what NEPA requires.”
Callaghan Complex and new “complex” configuration
Historically, the Callaghan Complex consisted of the Callaghan and New Pass–Ravenswood HMAs, but BLM has now reconfigured it to include South Shoshone, Bald Mountain, Hickison (north of U.S. 50), and the North Shoshone Herd Area—despite the fact that these areas are not contiguous and do not have documented and analyzed interchange. The lawsuit argues that this new configuration is an arbitrary construct designed to justify a large roundup, leaving wild horses confined to about 329,134 acres of more than 1.1 million acres in the planning area while maintaining “zero” AMLs in the North Shoshone and northern Hickison units.
“BLM is shoving these very different HMAs into one oversized gather plan for its own convenience, not because the land or the wild horses demand it,” Leigh said. “They walked away from HMA‑specific planning we were already working on back in 2017, permittees are now complaining, and they’re facing a staffing shortage—so instead of doing the hard, lawful work, they’ve thrown together a rushed, one‑size‑fits‑none plan that sacrifices wild horses to administrative convenience.”
What plaintiffs are asking the court to do
The plaintiffs ask the court to halt any implementation of the Callaghan Complex HMAP/Gather Plan until BLM fully complies with the Wild Horse Act, NEPA, FLPMA, and the APA. They also seek to vacate the plan and its Finding of No Significant Impact and Decision Record, and require the agency to develop lawful, science‑based, site‑specific management for these herds and their habitat.
Plaintiffs are represented by Greenfire Law PC, Berkley.
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