Throughout the late nineteenth and early twentieth centuries, the gray wolf was systematically eradicated from most of the lower forty-eight states. A population of hundreds of thousands was whittled down to a few hundred, concentrated only in the woods of Minnesota and Isle Royale, Michigan. The wolf has rebounded, thanks to robust federal protection. But full recovery remains elusive—in part because of the federal government’s narrow expectations for recovery.
In August 2017, the D.C. Circuit struck down a 2011 rule that removed the gray wolf from the endangered species list in the Western Great Lakes area. The court held that the U.S. Fish and Wildlife Service had impermissibly failed to consider how the loss of the gray wolf’s historical range affected the species’ overall survival outlook. This decision highlighted some long-recognized shortcomings of the Service’s interpretation of recovery under the Endangered Species Act, including its concentration on core populations to the detriment of peripheral ones. Focusing on the complex history of the gray wolf, this Note explores traditional justifications for species preservation, as well as justifications for a broader geographic recovery of a species. In doing so, it identifies a repertoire of principles that should inform future decisions about a species’ geographic restoration, and by reflecting on these principles, it argues for a more purposeful consideration of a species’ historical range.
