Saturday, May 4, 2013

Marsh v. Oregon Natural Resources Council case brief

Marsh v. Oregon Natural Resources Council case brief
490 U.S. 360 (1989)

CASE SYNOPSIS: Petitioners, Army Corps of Engineers and associated agencies, appealed the judgment of the United States Court of Appeals for the Ninth Circuit (Oregon), which reversed the district court's order denying relief to respondent nonprofit corporations for their National Environmental Policy Act of 1969, 42 U.S.C.S. § 4321 et seq., claims and permanent injunction of construction of a dam.

FACTS: Respondent nonprofit corporations filed an action seeking to enjoin petitioners, Army Corps of Engineers and associated agencies, from constructing a dam, claiming that petitioners violated the National Environmental Policy Act of 1969 (NEPA), 42 U.S.C.S. § 4321 et seq., by failing to prepare a second supplemental Environmental Impact Statement (EIS) to review information developed after the final EIS supplement (FEISS) was completed. After the appeals court reversed the district court's judgment for petitioners, petitioners appealed. The court reversed and remanded, holding that because petitioners' decision not to supplement the FEISS was not "arbitrary or capricious," was based on careful scientific analysis that the new information was of exaggerated importance, petitioners conducted a reasoned evaluation of the relevant information and reached a decision that was within the dictates of the NEPA. The information developed after the completion of the EIS did not require that a supplemental EIS be prepared before construction of the dam could continue.

CONCLUSION: The judgment was reversed and remanded.

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