Hells Canyon Preservation Council v. United States Forest Service

When a party withdraws one of its claims before the trial court enters judgment and the action is subsequently dismissed on the merits, does the trial court’s failure to indicate that the withdrawn claim was dismissed without prejudice necessarily render its decision a “final judgment on the merits” as to that claim? Because we answer this question in the negative, we reverse the district court’s dismissal of this suit on res judicata grounds and remand for further proceedings.

I

The Hells Canyon National Recreation Area (HCNRA), located on Oregon’s border with Idaho, was established by Congress in 1975 pursuant to the Hells Canyon National Recreation Area Act, Pub.L. No. 94-199, 89 Stat. 1117 (1975), 16 U.S.C. §§ 460gg et seq. The HCNRA includes the “Hells Canyon Wilderness,” which is defined as the area “depicted on the map entitled ‘Hells Canyon National Recreation Area’ dated May 1978, which shall be on file and available for public inspection in the officer of the Chief, Forest Service, United States Department of Agriculture.” 16 U.S.C. § 460gg(b). The Hells Canyon Wilderness is governed by the HCNRA Act or the Wilderness Act, 16 U.S.C. §§ 1131-36 , whichever is more…