By a vote of 6 to 5 in Organized Village of Kake v. USDA, a limited en banc panel of the Ninth Circuit (a creature unique to that circuit) ruled today that the USDA violated the Administrative Procedures Act twelve years ago—in 2003—when it supposedly failed to provide a reasoned explanation for exempting the Tongass (Alaska) National Forest from its 2001 “Roadless Rule” limiting road construction and timber harvesting in national forests.

In the lead dissent, Judge Milan Smith observes that the case “involves a clash between the policies of the outgoing Clinton administration and those of the incoming Bush administration.” He makes the understated point that “[t]here is nothing improper about the political branches of the government carrying out such changes in policy” and concludes that the USDA’s decision to follow President Bush’s policy instructions easily meets the requirements of administrative law. The majority implausibly claims that the USDA made a “factual finding” in 2001 that exempting the Tongass forest “would risk the loss of important roadless area value” and that the USDA in 2003 failed to provide a reasoned explanation for discarding that supposed finding. Smith soundly responds that what is at issue is a change in policy, not a change in factual findings.

Judge Alex Kozinski powerfully adds:

I write only to note the absurdity that we are in the home stretch of the Obama administration and still litigating the validity of policy changes implemented at the start of the George W. Bush administration. How can a President with a mere four or eight years in office hope to accomplish any meaningful policy change—as the voters have a right to expect when they elect a new President—if he enters the White House tethered by thousands of Lilliputian ropes of administrative procedure? The glacial pace of administrative litigation shifts authority from the political branches to the judiciary and invites the type of judicial policymaking that Judge Smith points out. This is just one of the ways we as a nation have become less a democracy and more an oligarchy governed by a cadre of black-robed mandarins. I seriously doubt this is what the Founding Fathers had in mind and worry about the future of the Republic if the political branches fail to take back the power the Constitution properly assigns to them.