THE CONTINUING BATTLE OVER WILDERNESS IN THE WEST: WHAT HAPPENS NEXT IN UTAH V. NORTON

Since Lujan v. National Wildlife Federation,' wilderness advocates have had varying levels of success in establishing standing to challenge land management policies. With the recent Utah district court decision in Utah v. Norton,' it seems the avenues wilderness advocates can pursue in their efforts to protect land through litigation are increasingly leading to dead ends. The Utah v. Nortondecision is the most recent product of over ten years of litigation, and the decision, like many in the realm of environmental litigation, hinged on the plaintiffs' lack of standing. In an effort to explore what remedies might still be open for wilderness advocates both in Utah and in the rest of the nation, this paper will review relevant statutes and case law, describe when the courts found that standing was adequate and when it was not, and how the Utah v. Norton litigation might proceed from here