Center for Biological Diversity, et al., v. The Bureau of Land Management, No. C 11-06174 PSG, 2013 U.S. Dist. LEXIS 52432 (N.D. Cal. Mar. 31, 2013)

(plaintiffs, environmentalist activist groups, challenge defendant's decision to sell four oil and gas leases for approximately 2,700 acres of federal land in two CA counties by seeking summary judgment on basis that leases were sold in violation of NEPA and Mineral Leasing Act of 1920; defendant also sought summary judgment; court determined that defendant violated NEPA with respect to environmental assessment of leases by unreasonably relying on earlier scenario that consider impact of hydraulic fracturing techniques ("fracking") when used in combination with horizontal drilling; defendant had determined that there would be no significant environmental impact and did not prepare environmental impact statement; court held that such position was erroneous as a matter of law; court ordered parties to determine next step for solution).