Good science almost invariably implies replication: that is, a decent sample size. Yet legal cases often concern only a single individual. In a dispute over a proposed clear-cut of spotted owl habitat, plaintiff had to demonstrate imminent harm to 'an identifiable animal.' It would be too costly for the government to detail and respond to the threats facing each owl, one owl at a time. Rather, forest plans allow the government to manage and protect entire populations. Surely one might hope for a rough congruence between the spatial scale of these planning activities and the spatial scale of the litigation arising from them. The news is not encouraging. Our legal system redresses grievances to individuals, not populations (with the exception of class actions)