The U.S. Supreme Court case D. Dean Bibles, Director, Oregon Bureau of Land Management v. Oregon Natural Desert Association (1996) centered around a dispute over the management of public lands in Oregon by the Bureau of Land Management (BLM). The Oregon Natural Desert Association challenged BLM's decision to renew grazing permits without conducting an environmental impact statement as required under the National Environmental Policy Act (NEPA). The Ninth Circuit Court sided with the association and ordered BLM to conduct an environmental review before issuing any new permits. However, on appeal, this ruling was reversed by the Supreme Court which held that NEPA does not require agencies like BLM to prepare an environmental analysis every time they make a discretionary decision related to previously issued land-use plans or policies unless there is significant new information about potential impacts.

In the dissenting opinion for D. Dean Bibles, Director, Oregon Bureau of Land Management v. Oregon Natural Desert Association (1996), Justice Scalia argued that the majority's interpretation of "major Federal action" under the National Environmental Policy Act was too broad and inconsistent with previous court rulings. He contended that a federal agency's decision to allow cattle grazing on public lands did not constitute a major federal action as it didn't significantly alter the status quo or have significant environmental impacts warranting an environmental impact statement (EIS). Furthermore, he criticized the majority for failing to provide clear guidance on what constitutes a major federal action requiring an EIS, which could lead to arbitrary decisions by lower courts in future cases. Scalia also disagreed with their view that allowing grazing without conducting an EIS violated NEPA because such actions were ongoing activities rather than discrete projects subject to NEPA review.