Seeing Red: Gibbs v. Babbitt

The reintroduction of the endangered red wolf into its historic range in North Carolina has proved a controversial endeavor. In 1988, the United States Fish and Wildlife Service (FWS) reintro- duced red wolves into the Alligator River National Wildlife Refuge (Refuge) in North Carolina pursuant to section 10(j) of the Endan- gered Species Act (ESA).1 The red wolves prospered, even though many migrated from the Refuge onto private lands.2 In response to public opposition, several counties in North Carolina enacted reso- lutions objecting to the reintroduction.3 North Carolina subse- quently enacted a statute that permitted the taking of the red wolf on private land under conditions that are more lenient than the federal regulation.