Ninth Circuit review editor's note.

• Author: King, Andrew
• Position: 2013 NINTH CIRCUIT ENVIRONMENTAL REVIEW

It is my privilege to present the 2013 Ninth Circuit Environmental Review. This review contains twenty-nine summaries of the Ninth Circuit Court of Appeals's decisions on environmental and natural resources topics, issued between March 2013 and March 2014. The review also includes two chapters authored by Ninth Circuit Review members. Both chapters closely examine issues raised by two summarized opinions.

In the first chapter, Whitney Magnuson analyzes the nexus between piracy law and marine conservation efforts. She examines the Ninth Circuit's decision in Institute of Cetacean Research v. Sea Shepherd Conservation Society and questions whether environmental goals should be construed as "private ends" for purposes of convicting a defendant as a pirate. She ultimately concludes that they should not.

In the second chapter, Corey Moffat explores the jurisdictional doctrine of standing in the context of climate change. He addresses the Ninth Circuit's recent decision in Washington Environmental Council v. Bellon and argues that the court misconstrued the Supreme...