West Virginia Division of Izaak Walton League v. Butz, 367 F. Supp. 422 (D. W.Va. 1973), affirmed, 522 F.2d 945 (4th Cir. 1975), was brought by the Izaak Walton League, Sierra Club, Natural Resources Defense Council, and others to enjoin the "clear-cutting" practices of the Forest Service in the Monongahela National Forest. The district court and the court of appeals held, under the Organic Act of 1897, that the Forest Service could allow only the cutting of mature timber in national forests, not young growing trees, and that each tree must be individually marked prior to sale. Congress passed the National Forest
Management Act of 1976 as a result of this decision, which modified the decision, but included forestry requirements providing substantially more environmental protection than previously existed.