The U.S. Supreme Court case Ohio Forestry Association, Inc. v. Sierra Club et al., 1997 revolved around the issue of whether a National Forest Management Act (NFMA) land and resource management plan could be challenged in court before it was implemented through site-specific actions. The Sierra Club sued to prevent logging in the Wayne National Forest under a new NFMA plan that they argued violated federal law by not adequately protecting certain species or considering environmental impacts sufficiently. However, the Supreme Court ruled in favor of Ohio Forestry Association, stating that such plans were not immediately actionable because they did not authorize any specific action nor command anyone to do anything; instead, these plans guide and constrain future agency decisions for project-level activities like timber harvesting or road building which would then be subject to challenge when proposed.

In the dissenting opinion for Ohio Forestry Association, Inc. v. Sierra Club et al., Justice Stevens argued that the Court should have allowed judicial review of a forest plan approved by the United States Forest Service because it had legal consequences and was final agency action under Administrative Procedure Act (APA). He believed that this case presented an actual controversy as required by Article III of Constitution since Sierra Club's members used and enjoyed forests affected by plan, which could lead to increased logging activities causing environmental harm. Furthermore, he contended that deferring judicial review until site-specific actions are proposed would result in inefficient piecemeal litigation and potentially irreversible environmental damage. Therefore, he disagreed with majority's decision to dismiss case for lack of ripeness.