Summary
In 1981, Sierra Club and others brought forth a case in the name of Palila (an endangered bird species in the ecosystem of Mauna Kea) as a plaintiff in its own right under the Endangered Species Act, contending that the Palila was harmed by the presence of mouflon sheep. The case affirmed that Hawaii’s game management practices involving feral goats and sheep violated the Endangered Species Act and constituted unlawful “taking” because the goats and sheep threatened the ecological capacity of the Mamane Forest, the natural habitat of the Palila. The Sierra Club reopened the case in 1984 to amend its original complaint to add mouflon sheep as destructive animals. The court ruled in favor of the Sierra Club in 1986 and again in an appeals case in 1988.