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The petition argues that the 1993 Recovery Plan's compartmentalized approach of managing grizzly bears in isolated recovery areas is outdated and fails to ensure long-term genetic and demographic resiliency. It proposes a unified metapopulation framework that manages bears as a single interconnected population across the Northern Rockies, requiring the establishment of natural connectivity and the implementation of stricter regulatory mechanisms to reduce human-caused mortality. The petitioners oppose current efforts by Idaho, Montana, and Wyoming to delist grizzly bears, asserting that recovery is premature without a connected metapopulation and durable protections against threats such as habitat fragmentation, climate change, and lethal management policies.

The Mexican gray wolf (Canis lupus baileyi) is one of North America's most endangered mammals, with a wild population of only 113 individuals as of February 2017. Historically found across the southwestern U.S. and Mexico, the subspecies was nearly eliminated by the livestock industry and government agents. Current recovery efforts are hampered by poor genetic diversity, as all existing wild wolves descend from just seven captive ancestors. Earthjustice argues that the U.S. Fish and Wildlife Service's 2017 Recovery Plan is flawed because it limits wolves to inadequate habitats, fails to provide sufficient wild releases, and ignores scientific recommendations to establish three interconnected populations totaling at least 750 individuals across Arizona, New Mexico, the Grand Canyon, and southern Colorado.

Earthjustice argues that the FWS proposal to delist gray wolves in the Northern Rockies is illegal and biologically unsound. The organization contends that the proposed DPS boundaries are arbitrary, demographic recovery goals are set too low to ensure long-term viability, and state regulatory frameworks in Idaho, Wyoming, and Montana are inadequate to protect wolves from aggressive killing. Furthermore, Earthjustice asserts that the FWS failed to account for habitat fragmentation from roading, the loss of historic range, and the lack of guaranteed funding for management activities.