Saturday, May 4, 2013

Kleppe v. Sierra Club case brief

Kleppe v. Sierra Club case brief
427 U.S. 390 (1976)

CASE SYNOPSIS: On a writ of certiorari, petitioners, the Department of the Interior and other federal agencies, sought review of the judgment of the United States Court of Appeals for the District of Columbia Circuit, which ruled in favor of respondent environmental organizations in their suit under the National Environmental Policy Act, 42 U.S.C. § 4321 et seq., seeking declaratory and injunctive relief.

FACTS: Several environmental organizations filed suit against the Department of the Interior and other federal agencies, claiming that they could not allow further development of the Northern Great Plains region without preparing a comprehensive environmental impact statement under § 102(2)(C) of the National Environmental Policy Act (NEPA), 42 U.S.C.S. § 4321 et seq., on the entire region. The Court held that the court of appeals erred in finding that NEPA required the federal agencies to prepare a statement on the entire region. The organizations could prevail only if there had been a report on a proposal for major federal action with respect to the Northern Great Plains region; however, all proposals were for actions of either local or national scope. The court of appeals' finding that the agencies were contemplating a regional development plan was not supported by the language or legislative history of NEPA. The court of appeals' injunction against the Department of Interior's approval of the mining plans was improper because there was no threat of irreparable harm. The agencies had not acted arbitrarily in refusing to prepare one comprehensive statement on the entire region.

CONCLUSION: The Court reversed the judgment of the court of appeals.

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