In American Wild Horse Campaign v. Raby, 2025 U.S. App. LEXIS 17410, __ F.4th. __ (10th Cir. July 15, 2025), the Tenth Circuit reversed and remanded a Bureau of Land Management (BLM) plan to manage southern Wyoming wild horse populations by reducing some horse populations to zero as arbitrary and capricious for failing to discuss the plan’s ecological balance.