This E&E News article sounds like it could apply to USFS and BLM cases. I’m not sure if it sets precedent or not. The 6th Circuit’s decision is here.
Amanda Reilly, E&E News reporter
Published: Friday, February 23, 2018
Citizens who don’t meaningfully participate at the planning stage of a federal action forfeit their ability to later challenge the environmental review of that action, a federal court ruled today.
The 6th U.S. Circuit Court of Appeals dismissed claims by a group of local residents challenging the National Park Service’s review of a scenic trail through Michigan’s Sleeping Bear Dunes National Lakeshore.
The plaintiffs can’t bring their claims because they didn’t raise their objections when NPS issued a revised plan for the trail, Judge John Rogers wrote for the court.