The Uncertain Future for Gray Wolves

Tuesday, December 13, 2022
  • The following is the opinion and analysis of the writer.
  • Use of this article or any portions thereof requires written permission of the author.


Oregon Department of Fish and Wildlife

Theodore Roosevelt once labeled the gray wolf “the beast of waste and destruction.” This label, and other similar labels, led to the nationwide overhunting of gray wolves in the United States. By 1960, the wolf population had quickly dwindled from near 2 million, to as little as 300 wolves in the lower 48 states. This started the rather tumultuous protection journey for the gray wolves.

The gray wolves eventually found protection under the Endangered Species Act (ESA), before their delisting in 2020. However, this delisting did not last long, as the species returned to the list not even two years later in 2022. Nonetheless, the state of recovery for the species remains unsettled, as even the strongest recovery populations in the Northern Rocky Mountains may soon return to the list following a 12-month finding period.[i]

ESA protection and delisting

It was not until 1978 that wolves landed a place on the endangered species list. At this time, the U.S. Fish and Wildlife Service (FWS) classified the gray wolf as endangered at the species level. Following recovery efforts, the Northern Rocky Mountains population was delisted in 2011 (except for the Wyoming portion of the range, which delisted in 2017), with the remaining wolf population delisted in 2020.[ii] This decision came after the FWS exceeded its recovery goals, returning the gray wolf population to over 6,000 in the lower-48 states. The agency hoped to develop a “more collaborative approach to protect the species, our economy and our communities” by returning management of gray wolf populations to the states.[iii]

Immediately following this 2020 delisting, many states including Michigan, Minnesota, Montana, and Idaho began planning and/or implementing wolf hunts. These hunts were set to have a devastating effect on wolf populations. Wisconsin, for example, killed 218 wolves in their 2021 “harvest,” “about 21 percent of the state’s 2020 population,” estimated at 1,034. This figure fails to account for natural deaths and unreported kills, making the population much lower. This rapid population removal harms the wolves’ reproduction process, making it difficult for the species to repopulate, and placing them in danger once again.[iv]

ESA relisting

Just one short year later, on February 10, 2022, gray wolves found themselves back on the endangered species list. All gray wolves in the contiguous 48 states and Mexico, except the Northern rocky population, are once again protected by the Endangered Species Act.[v]

This relisting came after numerous environmental groups filed lawsuits to regain protection for the gray wolf. On February 10, 2022, a U.S. District Court in California vacated the FWS’s decision to delist the gray wolf. In a single decision pertaining to three separate suits, the first being Defenders of Wildlife v. U.S. Fish and Wildlife Services, the court found that the FWS violated the Administrative Procedure Act (APA) by acting arbitrarily and capriciously. Notably, the agency based its relisting decision on specific geographic populations that experienced marked recovery    -- the Great Lakes and Northern Rocky populations -- but “failed to adequately consider the threats to wolves outside of [those] core populations.” Accordingly, the court found that the fate of these other populations could pose a significant threat to the viability of the gray wolf species if not protected, which required consideration.[vi]

On the flipside, some hunter advocacy groups have rejected this decision. These groups see the decision as a blow to “farmers, ranchers, and anyone who supports a balanced ecosystem with common-sense predator management.” These groups prefer predator management to come from local experts rather than bureaucrats who are unfamiliar with the areas they are controlling.[vii]

Nonetheless, the District Court decision has returned ESA protection to gray wolves. This means that it is now illegal to hunt and trap wolves outside of the northern Rocky Mountains. Any person who knowingly violates the ESA may be subject to criminal prosecution, including fines of up to $50,000 or imprisonment for up to a year, or civil penalties of up to $25,000 per violation.[viii]

Potential future protection for Northern Rocky Mountains populations

Although the District Court’s ruling does not extend protection to wolves in the Northern Rockies presently, on September 17, 2021, the FWS announced that they plan to initiate a status review to determine if relisting of this population of gray wolves is warranted. The agency requested public comment on scientific and commercial data before they issue a 12-month finding. This announcement was in response to an emergency petition from the Center for Biological Diversity and its partners. The FWS stated that the petition presented “substantial scientific or commercial information indicating that the petitioned actions may be warranted.”[ix]

By September 2023, we should expect to see a status review of the Northern Rockies gray wolves based on the public comment period. If the FWS deems further protection is not warranted, then the agency will publish a negative 12-month finding with the Federal Register and the path for protection ends. If the FWS finds further protection is warranted, the agency will publish a 12-month finding and proposed rule. This proposed rule will also be accompanied by a request for public comment. Following the comment period, the agency will respond to relevant comments and either withdraw the proposed rule or publish a final rule.[x]

If you wish to participate in the current public comment period, you can do so here:


[i] Annie B White, A History of Wild Wolves in the United States, Gray Wolf Conservation,

[ii] Gray Wolf, U.S. Fish & Wildlife Serv.,

[iii] Jonathan Shuffield, U.S. Fish and Wildlife Service Delists the Gray Wolf in the Lower-48 States, Nat’l Ass’n of Countries (Nov. 10, 2020),

[iv] Tess Joosse, Wolf Populations Drop as More States Allow Hunting, Sci. Am. (Sep. 7, 2021),

[v] 2022 Gray Wolf Questions and Answers, U.S. Fish & Wildlife Serv. (2022),

[vi] Cassi Ferri, Gray wolf listing reinstated under Endangered Species Act, The Wildlife Soc’y (Feb. 14, 2022), Defs. of Wildlife v. U.S. Fish & Wildlife Serv., 584 F. Supp. 3d 812 (N.D. Cal. 2022), judgment entered, No. 21-CV-00344-JSW, 2022 WL 503662 (N.D. Cal. Feb. 10, 2022).

[vii] Emma Tucker & Hannah Sarisohn, Federal judge reverses Trump era wildlife decision, restoring protections for the gray wolves, CNN (Feb. 12, 2022, 4:52 PM),

[viii] Federal Court Restores Gray Wolf’s Endangered Species Act Protection, Ctr. for Biological Diversity (Feb 10, 2022), Endangered Species Act, Section 11. Penalties and Enforcement, U.S. Fish & Wildlife Serv.,

[ix] Endangered and Threatened Wildlife and Plants; 90-Day Finding for Two Petitions To List the Gray Wolf in the Western United States, 86 Fed. Reg. 51857 (proposed Sep. 12, 2021) (to be codified at 50 C.F.R. pt. 17); Federal Court Restores Gray Wolf’s Endangered Species Act Protection, Ctr. for Biological Diversity (Feb 10, 2022),

[x] Office of Protected Resources, Listing Species Under the Endangered Species Act, NOAA Fisheries (Dec. 1, 2022),