The gray wolf has been listed as an endangered species since 1973. In 1995, the Department of the Interior and the United States Fish and Wild-life Service implemented the Northern Rocky Mountain Gray Wolf Recovery Plan (Recovery Plan), which was designed to bolster the endangered wolf population. Under the Recovery Plan, and pursuant to section 10(j) of the Endangered species Act, Canadian gray wolves were captured and released into Yellowstone National Park and central Idaho. The Recovery Plan has since been the subject of intense litigation by ranching groups over the last several years. The major allegation of the farm bureau federations is that the Recovery Plan, as implemented, violated section 1O(j), and these organizations want the reintroduced wolves removed. On January 13, 2000, the Tenth Circuit Court of Appeals delivered a major blow to the farm bureau federations involved in the litigation by holding that the Recovery Plan was conducted in full compliance with section lOW. The court ordered that the reintroduced wolves be allowed to stay in the recovery areas. The danger, however, to this and other reintroduction programs is not over. This Comment explores the legality of the Recovery Plan, ultimately endorsing a flexible reading of section 10(j) as it applies to the Yellowstone wolves, and offering such flexibility as a means of promoting future wildlife reintroduction programs
