The question
Whether the National Environmental Policy Act required the Surface Transportation Board to analyze the environmental effects of upstream oil drilling and downstream oil refining that are separate in time or place from the railway project it approved.
Seven County Infrastructure Coalition v. Eagle County
What the Court decided
The Court reversed the D.C. Circuit. It held that courts owe substantial deference to agencies in NEPA cases and that NEPA did not require the Surface Transportation Board to analyze the environmental effects of upstream oil drilling and downstream refining that are separate in time or place from the Uinta Basin Railway. NEPA is a purely procedural statute that prescribes process, not results, and the Board's task was to address the environmental consequences and feasible alternatives of the project at hand. The adequacy of an environmental impact statement matters only to whether the agency's final decision was reasonably explained.
How the justices split
8-0The Court's opinion
Kavanaugh, joined by Roberts, Thomas, Alito, Barrett
NEPA is a purely procedural statute that prescribes the process for an agency's environmental review and does not mandate particular results. Courts must apply substantial deference in NEPA cases, and the only role for a reviewing court is to confirm that the agency addressed the environmental consequences and feasible alternatives of the relevant project. Deference extends to an agency's determination of what details are relevant in an EIS, and the textual focus of NEPA is the proposed action rather than separate projects. The Board was not required to analyze the effects of upstream drilling and downstream refining that are separate in time or place from the railway.
Concurring in the judgment
Sotomayor, joined by Kagan, Jackson
Agreed with the judgment reversing the D.C. Circuit but wrote separately rather than joining the reasoning of the Court's opinion.
How we know · 5 sourced claims
The D.C. Circuit failed to afford the Board the substantial judicial deference required in NEPA cases.
Source: syllabus, Held
NEPA did not require the Board to consider the environmental effects of upstream and downstream projects that are separate in time or place from the Uinta Basin Railway.
Source: syllabus, Held
NEPA is a purely procedural statute that prescribes the necessary process but does not mandate particular results.
Source: syllabus, Held
Kavanaugh delivered the opinion of the Court, joined by Roberts, Thomas, Alito, and Barrett.
Source: syllabus, lineup
Sotomayor filed an opinion concurring in the judgment, joined by Kagan and Jackson, and Gorsuch took no part in the case.
Source: syllabus, lineup