The Rooster Town Blockade was a land occupation in Winnipeg, Manitoba that lasted from July 14 through September 15, 2017. The blockade aimed to prevent the destruction of an area known as the Parker Wetlands by Gem Equities, a property development company that intended to construct a housing development on the site. The land defenders were eventually compelled by a court order to leave the site, and, following their departure, Gem Equities destroyed what remained of the wetlands. Importantly, the blockade represented a coming together of environmentalist and Indigenous sovereignty movements in Winnipeg, and, through the extensive media coverage it received, the blockade forced the intersecting issues of environmental protection and Indigenous sovereignty to the center of public debate. I suggest that the blockade should be viewed not merely as a protest, but rather as an act of grassroots, “insurgent” urban planning. Through the assertion of an anti-colonial and environmentalist vision for the Parker Wetlands, it can be viewed as the creation of a new plan for the site, which was counter to that of the municipal government and private sector. I begin this article by describing and contextualizing the Parker Wetlands site. I then explore both conventional and “insurgent” planning practices. Finally, I examine the blockade itself. I reflect on the ways in which this blockade can be understood as an act of insurgent planning and what insights this framework offers other struggles to come.

The Location, Ecology, and Indigenous History of the Parker Wetlands

The Parker Wetlands were a section of a larger, undeveloped area located in south-central Winnipeg, between Waverly Street and Pembina Highway on the west and east respectively, and bound by a set of train tracks to the north and Parker Avenue to the south. The 20-acre portion now owned by Gem Equities is located in the northeast corner of this larger site. For years prior to the blockade, the Parker Wetlands were a site of tension in Winnipeg. Previously owned by the municipal government, the Parker Wetlands were transferred to Gem Equities in a controversial land swap arrangement. 1 The Wetlands were then designated as a “major redevelopment site” in the City of Winnipeg’s 25-year growth plan, to be developed in conjunction with the construction of a new bus rapid transit (BRT) corridor, which would run through the city-owned portion of the larger undeveloped site. 2 This BRT route, first proposed in 2012, was met with resistance by area residents and environmentalist groups like the Parker Wetlands Conservation Committee, who were concerned that the BRT would damage local ecosystems and encourage further development on ecologically sensitive areas. 3

The Parker Wetlands were a site of unique ecological significance in Winnipeg, as they were part of a larger natural area that contained aspen forest, wetland, and grassland habitats. The land held by Gem Equities was predominantly aspen forest and wetland, and, using the City of Winnipeg Ecologically Significant Natural Lands (ESNL) strategy rating system, was rated at predominantly “A” quality, the highest rating that can be given. 4 According to this rating system, “A” grade natural areas are “considered to have a plant community reflecting the natural heritage of the area around Winnipeg” and are “worthy of consideration for preservation based on that assessment alone.” 5 While this policy contains many rules and procedures for city-owned natural lands, it directs the city to view private landowners like Gem Equities “as partners in stewardship and preservation” but offers no mechanism to compel them to act as such. 6 A report commissioned by Gem Equities points out that aspen forest habitats are not threatened, and City of Winnipeg policy supports a hierarchy of “A” grade environments, where grassland habitats are considered to be more important than aspen forest habitats. 7 However, the forest on the property owned by Gem Equities was “generally recognized as being the largest and best remaining forest of this type that is located near the downtown.” 8 The well-used paths and trails through the aspen forest attested to its role as a valuable urban green space in Winnipeg.

Because of their proximity to 20th-century Métis communities, the Parker Wetlands are also part of Indigenous history in Winnipeg. The Wetlands were situated between the former locations of Tin Town to the south (near what is now McGillivray Boulevard) and Rooster Town to the north (near the intersection of Grant Avenue and Cambridge Street). 9 These were Métis communities that were built on municipally-held land at Winnipeg’s fringes in the early 20th century but were not formally recognized by the city. 10 During the 1930s, Rooster Town’s population grew to several hundred. Following the Second World War, city-sanctioned suburban development spread southward from central Winnipeg. Because many Rooster Town residents lacked formal title to the land they occupied, the expansion of the suburbs pushed Rooster Town further south towards the Parker Wetlands, moving just beyond the edges of the new developments. 11 As Winnipeg expanded, the land on which Rooster Town stood became increasingly more valuable. Development pressure increased throughout the 1950s, and in the spring of 1959 the City of Winnipeg offered residents a one-time cash incentive of between $50 and $75 to abandon their community. 12 The City evicted all remaining Rooster Town residents in the summer of 1959 to make way for the construction of a large shopping mall development and a public high school. 13

In line with centuries of settler-colonial processes of dispossession, displacement, and settlement, the City of Winnipeg bulldozed or burned the dwellings left behind by the displaced Rooster Town residents, leaving little physical evidence that the community ever existed. However, due to its proximity to both Tin Town and Rooster Town, the Parker Wetlands became a “preserved archeological site of sorts” where structures, tools, and other remnants of its historical uses by Indigenous people remained. 14 The Wetlands were used by Indigenous people for hunting and trapping, gathering medicine, and conducting ceremonies, making them a place of significance in Winnipeg. 15 In a statement to APTN News, the Manitoba Métis Federation acknowledged this connection between the Parker Wetlands and Rooster Town and called for a moratorium on the clear cutting of the lands. 16 Despite the destruction of Rooster Town, the Indigenous histories of the Parker site have not been forgotten.

Urban Planning in Canada

The Canadian Institute of Planners (CIP) defines urban planning as “the scientific, aesthetic, and orderly disposition of land, resources, facilities and services with a view to securing the physical, economic and social efficiency, health and well-being of urban and rural communities.” 17 Initially, planning in Canada was done by colonial officials and military engineers, specifically with the purpose of facilitating colonial governance, resource extraction, and land provisions to settlers. 18 While the location of Indigenous communities may have influenced the placement of early colonial settlements, Indigenous community designs were ignored by early settler planning. 19 In this early stage, the “orderly disposition of land” meant the creation of maps, surveys, and boundaries that facilitated the creation of a private property system that could be efficiently governed from imperial Britain. 20 Rooted in these colonial histories, planning has since evolved into an exclusive profession, entry into which is regulated and restricted by academic institutions and professional associations. 21 While various techniques and outlooks have been debated in planning literature, Canadian planning, like most Western planning traditions, has historically been dominated by an objective professional viewpoint (rational-comprehensive planning) in which planners––especially those in government––are seen as apolitical bureaucrats working towards a general public interest. 22

The history of Winnipeg, however, illustrates the explicitly political nature of planning in the “public interest.” Manitoba itself was created out of a struggle for Métis self-determination. This struggle led to the Manitoba Act of 1870, which created Manitoba as a province of Canada, and functioned as a nation-to-nation treaty that guaranteed the rights of the Métis to 1.4 million acres of land, as well as political self-determination. 23 The Manitoba Act did not address Crown-Anishinabe relations, and in 1871 they were formalized through the signing of Treaty 1. 24 Despite the promises of these treaties, the Canadian state used these documents—backed by heavily-armed military support—to create “a regime of private property” wherein Indigenous land uses were “incompatible with both the coming private property grid and … the exploitation of land inherent to export-agricultural and industrial capitalism.” 25 The Manitoba Act and Treaty 1 both encompass the land upon which urban and suburban Winnipeg now stands. Indigenous conceptions of land and property have been steadily marginalized in the process of settler colonialism, naturalizing the conception of the Canadian city as a place exclusive to settlers, where “Native spaces in the city are now being treated as urbs nullius—urban space void of Indigenous sovereign presence.” 26 The myth of urbs nullius is perpetuated by Canadian municipalities through the destruction of Indigenous communities such as Rooster Town, the annexation of reserve lands within municipal borders, and the rewriting of Indigenous histories as they pertain to cities. 27 These actions are in the service of the white settler public, clearly demonstrating the orientation of state planning aims. It was in this larger context that suburban expansion onto so-called vacant land pushed the residents of Rooster Town further south towards the Parker Wetlands and, I argue, it remains the context that permitted the exploitative development of the Parker Wetlands in 2017.

As Winnipeg’s history demonstrates, the concept of “public interest” planning in Canada is anything but apolitical. In the planning of 20th-century Halifax, the pervasive “scientific racist” worldview was a primary factor influencing planning decisions, which in turn directly discriminated against Black residents in Africville. 28 While planners and municipal officials—who were almost exclusively white at the time—claimed to act in the public interest, the “public” they considered was built upon a racial hierarchy and intentionally excluded Black people from its vision. 29 These political and racial underpinnings to planning practices are not simply the result of individual biases of planners, but connected to broader structures of state violence. Referencing the colonization of Palestine, Oren Yiftachel argues that, despite the best intentions or personal politics of individual planners, planning “imposes controls that reflect elite interests” as a practice that “[is] sanctioned, empowered, and implemented by the state.” 30 In settler-colonial states, the planning apparatus (modern planners, colonial surveyors, military engineers, etc.) is directly involved in “the processes of marginalising, removing and containing Aboriginal people within and beyond cities and towns.” 31 As exemplified above, state-led planning throughout Canada has been an important tool for the foundation and maintenance of the colonial state, which relies on the historical and ongoing dispossession of Indigenous peoples from their territories. This necessarily presents a problem for planning and its relationship to the so-called public interest. The foundation of the Canadian colonial state rests on this dispossession, and this logic cannot be divorced from its bureaucratic apparatuses. In this way it is clear that, despite claims to a professional objectivity or an idealized common good, institutionalized planning in Canada is necessarily embedded in a range of unjust power dynamics and structures.

Insurgent Planning

Insurgent planning practices offer a compelling alternative to the top-down, state-led practices that dominate planning in Canada. Building on earlier scholarship on radical strains of planning theory, 32 insurgent planning conceptualizes planning not as a practice carried out or mediated by technocrats, but rather views “practices of citizens and local communities as a form of planning” and emphasizes “taking seriously the practices of subordinate groups in shaping … plans, policies, and spaces.” 33 Whereas rational- comprehensive planning is focused on the “planner” as the primary actor and mediator of specialized knowledge, insurgent planning is democratic and action-oriented, focusing on what is being done, rather than who is doing it. 34 Insurgent planning is “aimed at challenging conventional planning by the state” through an oppositional practice grounded in the needs and abilities of a group or community. 35 In Faranak Miraftab and Shana Wills’ conception of insurgent planning, importance is placed on differentiating between “invited” and “invented” spaces of participation, the former consisting of spaces and actions where the dominant classes are comfortable with some degree of confrontation or participation (for example, a public consultation), and the latter being spaces where participation exists, but is repressed or criminalized (such as a land occupation). 36 While this conception of planning is necessarily broad to encompass the multitude of activities that could be insurgent planning, Miraftab offers some useful clarifications:

Insurgent planning practices are characterized as counter- hegemonic, transgressive and imaginative. They are counter- hegemonic in that they destabilize the normalized order of things; they transgress time and place by locating historical memory and transnational consciousness at the heart of their practices. They are imaginative in promoting the concept of a different world as being, Walter Rodney says, both possible and necessary. 37

At its core, the framework of insurgent planning allows for the imagining, creation, and analysis of planning beyond state-sanctioned channels and actors. By focusing on actions and not a limited list of actors, the practices of subaltern groups can be seen as acts of planning, creating a popular democratic planning framework that exists in opposition to the nominally representative state apparatus. 38

Because of the various kinds of activities that are considered insurgent planning practices under Miraftab’s definition, some examples may be useful here. Avinoam Meir explores the actions of Bedouin communities facing state-directed resettlement in Israeli-occupied Palestine. 39 In order to undermine Bedouin challenges to state land ownership claims in the Naqab desert, in the 1960s, the Israeli government began a long-term program of relocating Bedouin people from rural communities (which the Israeli state did not recognize) into state-planned towns. 40 These resettlements threatened both Bedouin land claims as well as traditional values and practices, and in response to these threats, Bedouin communities undertook a series of insurgent planning efforts. In the 1990s, these Bedouin communities established the Bedouin Committee for Strategic Planning (BCSP) to advance their planning interests against a hostile apartheid state and the Regional Council for Bedouin-Arab Unrecognized Villages (RCBUV), a shadow government to represent their interests in a coordinated way. 41 The BCSP engaged in a program of formalizing unrecognized Bedouin villages, posting place-name signs to demonstrate their newly “formal” status, and the RCBUV facilitated village council elections and acted as a regional government which represented the interests of the numerous unrecognized villages that were excluded from state political processes. 42 In opposition to Israeli state-planning schemes, the RCBUV created an alternative regional plan, which recognized and formalized the rural Bedouin communities and allowed for the meaningful participation of Bedouin people in political and planning processes. 43 The assertion of a planning agenda that was counter to state aims can be seen as an example of insurgent planning, and while the whole agenda was not implemented, the mobilization of these Bedouin communities has won gains in municipal service provision and increased political representation. 44

In another example, Miraftab and Wills discuss poor peoples’ struggles against eviction in Cape Town, South Africa. Despite constitutional guarantees of access to adequate shelter and services like water and electricity, the post-Apartheid government’s marketization of housing programs and privatization of services led to the evictions and service cut-offs for thousands of poor Black people in Cape Town in the late 1990s and early 2000s. 45 In response, affected people created the Anti-Eviction Campaign (AEC) and the Anti-Privatization Forum (APF) to combat the evictions and cut-offs and also to assert their constitutional rights to housing and service provision. 46 The AEC is highly localized and is primarily concerned with moving evicted people back into their homes and reconnecting disconnected services, and the APF links this localized struggle for housing to a nationwide campaign against a wider neoliberal state agenda. 47 In this context, the practical, harm-reducing actions of the AEC are connected to the APF’s struggle for an alternative state agenda, representing tangible steps towards a future where the constitutional rights to housing and service provision are upheld for all citizens.

From these examples it is clear that insurgent planning can take a wide variety of forms. Importantly, activists in both cases were either excluded from or subverted invited spaces of participation, and invented new spaces to assert alternative futures. The connection of the localized actions of the BCSP and AEC to larger campaigns effectively linked local and national struggles and made clear the connections between small-scale actions and a larger transformative agenda. This changes the nature of these local actions, shifting them from reactive protests to proactive assertions of an alternative future. Despite the different tactics employed in each struggle, all of these actions demonstrate the key tenets of Miraftab’s conception of insurgent planning. Both cases challenge the existing order, they are transgressive in practice, and, most importantly, they envision a tangible and improved human environment.

The Rooster Town Blockade

The Rooster Town Blockade was formed in July 2017 to prevent the further clear-cutting of the aspen forest in the Parker Wetlands initiated by Gem Equities. The blockade was a land occupation carried out by a group of around 50 individuals from a wide range of backgrounds and affiliations, including Indigenous land defenders and elders, members of the American Indian Movement and Urban Warrior Alliance, settler environmentalists, union members, and area residents. 48 Land defenders sought to protect the site’s unique ecology and highlight its importance as a historical and cultural site for many local Indigenous people. Its creation was motivated by

respect for Métis and First Nations sovereignty, destruction of pristine animal habitats, precious wetlands, prairie plants and beloved green space, and an overall lack of consultation with the surrounding community, local First Nations and the Métis community. 49

While formed to address the immediate need to save the forest, the Rooster Town Blockade also called for changes to the development processes regarding the site, demanding that all development on the site be halted until Treaty 1 First Nations and the Manitoba Métis Federation were consulted. 50

The two-month-long blockade was left in a curious stasis for much of its existence. Land defenders were occupying a site thatwas privately held by Gem Equities, however, two weeks into the occupation, a Court of Queen’s Bench justice determined that it was not necessary to hold an immediate hearing on whether or not to grant an injunction, as the land defenders did not threaten public safety. 51 Without an injunction from the courts, the Winnipeg Police Service, apparently unwilling to further escalate the situation, committed to “monitoring the ongoing dispute” and took no action to dismantle the blockade. 52

This did not prevent Gem Equities owner Andrew Marquess from taking his own action against the blockade. Diesel-powered construction lights were erected at the site, turned on nightly from 11:00pm through 6:00am and aimed at the tents of land defenders. Signs announcing 24-hour video monitoring were put up around the site, and land defenders were video-recorded by private security personnel. 53 Additionally, “the site’s project manager has showed up at around 6:30am to wake the campers and loudly proclaim—while filming the scene on his phone—that the land is ‘private property.’” 54 The initial decision to not grant an injunction hearing was overturned by the Manitoba Court of Appeal on August 30, 2017 and, on September 14, an injunction was granted against the land defenders. 55 The Rooster Town Blockade peacefully dispersed as a result of this court order on September 15, 2017.

Despite the dismantling of the blockade, its effects are still felt in Winnipeg. In October 2017 Gem Equities owner Andrew Marquess filed a lawsuit for between $500,000 and upwards of $10 million, ostensibly for damages incurred as a result of the blockade, naming 49 (alleged) Rooster Town Blockade land defenders as defendants. 56 This lawsuit not only threatens the land defenders, but also appears to be aimed at deterring any similar grassroots actions in the future through what is known as a “strategic lawsuit against public participation” (SLAPP). 57 Land defenders have committed to fighting the lawsuit in order to protect the rights of future activists. 58 Since the blockade was dismantled, the aspen forest has been entirely cut down. 59 In the most recent manifestation of this conflict, Winnipeg city councillor John Orlikow (whose ward included the Parker Wetlands) was investigated by the City of Winnipeg’s integrity commissioner as a result of complaints filed by Marquess for (among other things) “encourag[ing] a protest that trespassed on the developer’s land.” 60 This complaint stems from an offer Orlikow made to act as a mediator between the developer and land defenders, and while no wrongdoing was found, Orlikow issued an official apology for his actions. 61

The Rooster Town Blockade as Insurgent Planning

Rather than being viewed as simply a protest, the Rooster Town Blockade should be viewed as an act of insurgent planning. Through its challenging of the primacy given to settler private property at the expense of Indigenous land and histories, as well as the blatant disregard for environmental concerns exemplified by this development, the Rooster Town Blockade demonstrated a counter-hegemonic praxis. In occupying private property and restricting actions on it, the blockade (briefly) challenged settler-colonial capitalist property relations and demonstrated alternative conceptions of land and land use. The blockade was transgressive of time and place through the deliberate linkage of modern development to both recent and older Indigenous histories on the territory of what is now known as Winnipeg. The blockade, through its assertion of Indigenous sovereignty and its centering of the history of Rooster Town, which had been effectively erased, demonstrated the unchanging colonial nature of the Canadian state. The blockade further demanded a future in which Indigenous sovereignty is respected and upheld. It advocated for a future in which ecological concerns are taken seriously and where the use value of an irreplaceable site like the Parker Wetlands supersedes its exchange value. In the Parker Wetlands’ recent history, invited spaces of participation have offered little to those concerned about the site. Considering this, the invented space of the Rooster Town Blockade was the last remaining option. Using Miraftab’s conception, the Rooster Town Blockade is clearly an act of insurgent planning.

While the Rooster Town Blockade was unable to prevent the destruction of the Parker Wetlands or secure the involvement of Indigenous organizations in the development process, it is nevertheless an example of the potential of insurgent planning through direct action. The blockade halted development for two months and built a coalition of solidarity across a number of different activist groups and causes. 62 It demonstrated the relative ease with which a small group of committed participants could have a significant impact on planning schemes in Winnipeg, which will hopefully facilitate future actions against destructive development practices. It further forced the topic of Indigenous land and treaty rights to the forefront of popular media coverage of the blockade and publicly challenged the legitimacy of private property rights and settler governance on stolen land. 63 While it is too early to observe the greater impact of the blockade on future political action in Winnipeg, Victoria A. Beard’s work on grassroots planning and capacity building suggests that participants in insurgent planning actions may increase their capacity for further action merely by being involved. 64 Despite these successes, however, the limitations of this type of action should not be overlooked.

As participants were forced to lift the blockade in the face of state repression, the Rooster Town Blockade is also an example of some of the limitations of extra-legal insurgent planning. The foremost of these is the clearly uneven power dynamic between the public and state/corporate institutions. In occupying privately- held land, the Rooster Town Blockade land defenders confronted not only a development corporation, but also struggled against the larger system of private property rights rooted in colonial land theft. This was of course an enormous task, and the primacy of private property rights was predictably emphasized in the court ruling that ultimately ended the blockade. 65 The fragility of insurgent planning actions is also highlighted by the blockade, which, as an extra-legal, authority-challenging action existed only as long as the state permitted it to do so. In this way insurgent planning actions are at the mercy of authorities if they aim to both challenge state authority and also remain nonviolent. As the ongoing SLAPP suit demonstrates, this tactic also carries significant personal risks for the land defenders involved and may deter individuals from participating in similar actions in the future.

What Does the Insurgent Planning Framework Offer Activists?

Having examined the Rooster Town Blockade through the lens of insurgent planning, a pressing question arises: what does the insurgent planning framework contribute to actual practices on the ground? I believe it offers two key conceptual insights to activists and organizers: it reclaims urban planning from the domain of the state, and it provides a coherent, future-oriented framework through which to organize.

As discussed earlier, planning in Canada is primarily considered to be the exclusive domain of professional government or private sector actors. Reconceptualizing urban planning as an activity that can be directly democratic and de-professionalized offers an important insight to land-based struggles, particularly those in urban environments. Seeing the Rooster Town Blockade as an act of insurgent planning allows for common people to force the allegedly “apolitical” field of planning for the so-called “public interest” into the domain of popular politics. Along with the examples from Palestine and South Africa, the Rooster Town Blockade demonstrates that insurgent urban planning actions have led to real, material gains for people asserting sovereignty against settler-colonial states. The lens of insurgent planning legitimizes the actions of people excluded by colonial planning practices and reaffirms the possibility of a small but dedicated group having a tangible impact on the formation and future of their environment.

The future-oriented nature of insurgent planning is also a valuable aspect of this framework. While it could be reasonably assumed that any protest hopes to affect the future, insurgent planning consists of the assertion of a tangible, alternative future vision. Given the current political climate across much of Canada, it is easy for progressive organizations and mobilizations to exist in a perpetual state of defensiveness as they constantly respond and react to shifts in the political terrain. While understandable in the face of neoliberal attacks on social services and programs, the insurgent planning framework allows for an approach to organizing that takes us beyond these immediate issues and towards imagining new futures. Insurgent planning practices prioritize action over reaction. The Rooster Town Blockade was a struggle for both the specific goal of preventing the destruction of the forest and also the future goal of the exercise of Indigenous sovereignty in Winnipeg, moving beyond reaction into future-oriented action with tangible goals. The inability of the blockade to prevent the destruction of the Parker Wetlands should not be examined in isolation, but rather as one manifestation of a larger mobilization for Indigenous sovereignty and responsible environmental stewardship. While the wetlands were destroyed, other opportunities to assert the alternative future articulated by the Rooster Town Blockade will present themselves.

Not all political actions achieve its goals, but the future-oriented framework of insurgent planning allows for the creation of overarching conceptual and theoretical linkages between a variety of site-specific actions. By linking local actions to a larger future vision, individual actions can be evaluated in terms of their contribution to the larger counter-hegemonic struggle, rather than only by their individual outcomes. In this way, the Rooster Town Blockade is a notable urban manifestation of ongoing struggles for Indigenous sovereignty against the Canadian state, even though it was unable to complete its local goals of preventing the destruction of the Parker Wetlands and mandating the consent of Indigenous nations for land-use decisions.

Considering these two aspects together, the insurgent planning framework can be seen as a theoretical lens that allows for the coherent integration of seemingly disparate struggles across Canada. For example, organizing for transit justice in Winnipeg and in Toronto can be seen as local manifestations of the same people-led planning project, and the alternative future fought for in the Rooster Town Blockade can be linked to struggles for Indigenous sovereignty in Wet’suwet’en territory. As Beard notes, “we must begin to recognize how, cumulatively, modest efforts are capable of creating a sense of collective agency and the social and political spaces for radical action.” 66 Insurgent planning offers both a framework for the analysis of these efforts, and a useful theoretical underpinning for activists and organizers engaging in them.

Conclusion

The Rooster Town Blockade offers a compelling example of the ways in which insurgent planning practices empower the public. The blockade, formed as the result of the exclusion of the public in the planning process, offered a way for those who have been excluded by the practices of the colonial state to meaningfully participate in shaping their environment. The extra-legal nature of the blockade may have made the action inaccessible or unappealing to some however, the role of institutional planning in ongoing colonial processes of dispossession also represents a hostile and exclusionary practice. In this way, anti-colonial insurgent planning actions like the Rooster Town Blockade can be viewed as an alternative to state or market-led planning schemes that cannot (and will not) challenge the status quo.

The Rooster Town Blockade demonstrates the radical possibilities of insurgent planning. Through its centering of Indigenous land struggles, the blockade changed the media narrative surrounding land development in Winnipeg, and more largely challenged the primacy of private property and settler governance of stolen lands. The intersections of this struggle with wider environmentalist campaigns further built a coalition of solidarity against the destructive private development of culturally and environmentally important areas. These actions were undertaken without the assistance or involvement of the municipal government and represent an alternative to state-mediated planning initiatives. However, the limits of such actions, as exemplified by the collective lawsuit that the land defenders face, should not be ignored by other activists, and for future actions to be more successful, steps must be taken to mitigate such threats. *