Review editor's note.

AuthorWatkins, Rebecca

It gives me great pleasure to present the 2003 Ninth Circuit Environmental Review. This Review issue includes case summaries of the natural resource and environmental decisions of the Ninth Circuit Court of Appeals from approximately March 2003 to March 2004. It also includes two student Chapters discussing significant Ninth Circuit cases.

Ninth Circuit Review Members are selected from Environmental Law's yearly writing competition based on their excellent writing skills. Along with the typical source-checking duties of first-year members, Ninth Circuit Review Members write case summaries for this Review issue, as well as Chapters focusing specifically on Ninth Circuit cases. The two Chapters chosen for this Review address important issues in the environmental law field. Ms. Amie Jamieson discusses the interaction between the Endangered Species Act (ESA), the Bald and Golden Eagle Protection Act (BGEPA), and the Religious Freedom Restoration Act (RFRA) in United States v. Antoine. She cautions that delisting eagles under the ESA should not be used as the sole basis to eliminate statutory protection of bald eagles under a RFRA challenge to...

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