Environmental groups challenged several plans approved by the Department of the Interior for oil exploration and development in the Gulf of Mexico after the Deepwater Horizon accident. In a group of consolidated cases, the Fifth Circuit dismissed the challenges on procedural grounds. See, e.g., Gulf Restoration Network v. Salazar, No. 10-60411 (May 30, 2012). Among other holdings, the Court found that the groups had standing as organizations to sue, op. at 8-10, and that case law about the effect of an agency’s allegedly “illegal [and] clandestine” internal policies did not excuse the groups’ failure to exhaust administrative remedies here. Op. at 29.
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