COMPLAINT - 3
JURISDICTION AND VENUE
6. Jurisdiction is proper in this Court under 28 U.S.C. § 1331 because this action arises under the laws of the United States, including the National Environmental Policy Act, 42 U.S.C. §§ 4331,
.; the Federal Land Policy and Management Act, 43 U.S.C. §§ 1701,
.; and the Administrative Procedure Act, 5 U.S.C. §§ 551,
. 7. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(e) because Defendant BLM has offices in this judicial district, and a substantial part of the events or omissions giving rise to the claims in this Complaint occurred in this judicial district, and a substantial part of property that is the subject of this case is situated in this judicial district. 8. Venue is proper in the Southern Division of this District, as the challenged decision impacts federal lands and resources in Clark, Lincoln, and White Pine Counties.
L.R. 6-1, 8-1. 9. An actual, justiciable controversy exists between Plaintiff and Defendants, and the requested relief is proper under 28 U.S.C. §§ 2201-02.
10. Plaintiff Center for Biological Diversity (“the Center”) is a nonprofit conservation organization with more than 50,000 members dedicated to the preservation, protection, and restoration of biodiversity and ecosystems throughout the world. The Center has members who reside in Clark, Lincoln, and White Pine Counties, Nevada. 11. The Center has offices in a number of states, including Las Vegas, Nevada. The Center works to insure the long-term health and viability of animal and plant species across the United States and elsewhere, and to protect the habitat these species need to survive.
Case 2:14-cv-00226 Document 1 Filed 02/12/14 Page 3 of 32