In 2004 Courtney led a team that summarized all scientific information regarding the Northern Spotted Owl.
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The plaintiff argued that the red cockaded woodpecker (Picoides borealis), an endangered species, and the northern spotted owl (Strix occidentalis caurina), a threatened species, had injured them economically preventing them from conducting commercial business in the forestry industry.
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She further discusses proximate causation," which introduce notions of foreseeability." 'Harm' applies to significant habitat modification, which foreseeably causes the actual injury or death to the red cockaded woodpecker and northern spotted owl protected under the ESA.