On June 21, 2010, the U.S. Supreme Court overturned a decision of the U.S. Court of Appeals for the Ninth Circuit that upheld a blanket, nationwide injunction against the future marketing, distribution, and planting of a genetically modified crop. In reversing the appeals court, the Supreme Court reaffirmed its previous holding that an injunction is a drastic remedy that does not automatically issue against proposed federal activity, even where a federal agency has not adequately completed an environmental impact review required by federal environmental law. The decision was a victory for WLF, which filed a brief in the case arguing that, even when a NEPA violation has been established, important constraints of equity require that an injunction be denied unless the plaintiff demonstrates that he will suffer irreparable harm in the absence of an injunction.