On petition for writ of certiorari to the United States Court of
Appeals for the Fourth Circuit.
The petition for a writ of certiorari is denied.
Justice WHITE, with whom Justice BRENNAN and Justice MARSHALL
join, dissenting.
In 1982, the city of Norfolk sought permission from the Army
Corps of Engineers to construct a 298-slip marina at the site of an
abandoned ferry and near two existing marinas. [ Gee v. Boyd
471 U.S.
1058 (1985) ][1058-Continued.]
The Corps issued an "environmental assessment" 1 concerning the
project, which concluded that the socioeconomic benefits of the
project outweighed its likely adverse impact on the aquatic
ecosystem. The Corps further concluded that the project would not
"significantly affect . . . the quality of the human environment,"
see 42 U.S.C. 4332(2)(C), thereby making unnecessary the
preparation of an environmental impact statement ( EIS). On the
same day, the Corps issued a permit to the city clearing the
project.
Petitioner, a partner in a venture that owns property near the
site of the proposed marina, subsequently filed suit, challenging,
inter alia, the Corps' failure to prepare an EIS.2 The District
Court granted summary judgment to respondents and denied
petitioner's cross-motion for summary judgment. On appeal, the
Court of Appeals for the Fourth Circuit, like the District Court,
employed an "arbitrary and capricious" standard in reviewing the
agency's determination that the proposed marina would have no
significant effect on the environment. Gee v. Hudson,
746 F.2d
1471 ( 1984). See also Webb v. Gorsuch,
699
F.2d 157, 160 (CA4 1983); Providence Road Community Assn. v.
EPA,
683 F.2d
80, 82 (CA4 1982). The court held that neither this finding,
nor the agency's failure to consider the effect of possible future
marinas on the environment, was arbitrary or capricious.
Page 471 U.S.
1058 , 1059
The decision below is the most recent in a long line of cases
that have used divergent standards of review to assess an agency's
failure to prepare an EIS. The First, Second, and Seventh Circuits,
like the Fourth, will reverse such agency action only if it is
arbitrary or capricious. See Grazing Fields Farm v. Goldschmidt,
626 F.2d
1068, 1072 (CA1 1980); Hanly v. Kleindienst,
471 F.2d
823, 828-829 (CA2 1972), cert. denied, 412 U.S. 908 (1973);
Nucleus of Chicago Homeowners Assn. v. Lynn,
524
F.2d 225, 229 (CA7 1975), cert. denied sub nom. Nucleus of
Chicago Homeowners Assn. v. Hill, 424 U.S. 967 (1976). Four other
Circuits have employed a " reasonableness" standard of review. See
Save Our Ten Acres v. Kreger,
472 F.2d
463, 466 (CA5 1973); Winnebago Tribe of Nebraska v. Ray,
621 F.2d
269, 271 (CA8), cert. denied, 449 U.S. 836 ( 1980); Foundation
for North American Wild Sheep v. United States Dept. of
Agriculture,
681 F.2d
1172, 1177-1178 (CA9 1982); Wyoming Outdoor Coordinating
Council v. Butz,
484 F.2d
1244, 1248-1249 (CA10 1973).3 The Third Circuit has assumed,
without deciding, that a "reasonableness" standard is appropriate,
Township of Lower Alloways Creek v. Public Service Electric &
Gas Co.,
687 F.2d
732, 741-742 (CA3 1982), and the Sixth Circuit has similarly
declined to choose between the two standards. Boles v. Onton Dock,
Inc.,
659 F.2d
74, 75 (CA6 1981). The Court of Appeals for the District of
Columbia has developed a four-part test to determine whether the
agency action is arbitrary and capricious. Sierra Club v. Peterson,
717 F.2d
1409 (1983).4
Page 471 U.S.
1058 , 1060
This conflict is not merely semantic or academic. Certainly,
there are individual cases in which application of one standard
rather than the other makes no difference. But the lower courts
that have wrestled with the question of what rule to adopt clearly
have not viewed the issue as one that might be settled by the flip
of a coin. Courts that have chosen the "reasonableness" standard
have relied on the importance of "the basic jurisdictional-type
conclusion involved," 5 or on the "mandatory nature" of the
statute's language. [
Footnote
6] In settling on this more stringent rule, the Court of
Appeals for the Fifth Circuit expressed the concern that "[t]he
spirit of the Act would die aborning if a facile, ex parte decision
that the project was minor or did not significantly affect
environment were too well shielded from impartial review." Save Our
Ten Acres, supra, 472 F.2d, at 466. In contrast, courts adopting
the "arbitrary and capricious" test have emphasized that the
decision not to prepare an EIS is one committed to the agency's
discretion 7, and that application of a more deferential standard
"permits the agencies to have some leeway in applying the law to
factual contexts in which they possess expertise." 8 The Court of
Appeals did not state in this case that it would have reached the
same result under a "reasonableness" standard,9 and it is not for
us to say what conclusions it might have drawn had it applied
different considerations to these facts.
The lower courts have long been in disarray on what standard of
review to apply to an agency's decision not to undertake an EIS. I
would grant certiorari to end this confusion.
Footnotes
Footnote 1 An "environmental
assessment" is a brief document that the Army Corps of Engineers
prepares in order to determine whether a proposed action will have
a significant effect on the human environment. If such an effect is
anticipated, a more detailed "environmental impact statement" is
required under 42 U.S.C. 4332(2)(C). See App. to Pet. for Cert. at
15a-16a, n. 1.
Footnote 2 Petitioner also
contended that respondents failed to consider all reasonable
alternatives and mitigation measures as required by 42 U.S.C.
4332(2)(E), and that they had failed to verify certain financial
data submitted by the applicant. These claims were rejected by the
lower courts.
Footnote 3 The Eleventh
Circuit has adopted as binding decisions of the former Fifth
Circuit rendered prior to October 1, 1981. Bonner v. City of
Prichard,
661 F.2d
1206 (CA11 1981) (en banc). Therefore, the Eleventh Circuit
would presumably employ a "reasonableness" standard in reviewing
the failure to prepare an EIS statement.
Courts that have applied a "reasonableness" standard have
generally placed an initial burden on the plaintiff of raising a
"substantial environmental issue concerning the proposed project,"
after which the burden shifts to the agency to demonstrate the
reasonableness of its negative determination. See Winnebago Tribe
of Nebraska v. Ray, 621 F.2d, at 271. See also Foundation for North
American Wild Sheep v. United States Dept. of Agriculture, 681
F.2d, at 1178; Pokorny v. Costle,
464 F.
Supp. 1273, 1276 (Neb.1979).
Footnote 4 The test used by
the District of Columbia Circuit in scrutinizing an agency's
finding of "no significant impact" is:
"(1) whether the agency took a 'hard
look' at the problem;
"(2) whether the agency identified
the relevant areas of environmental concern;
"(3) as to the problems studied and
identified, whether the agency made a convincing case that the
impact was insignificant; and
"(4) if there was an impact of true
significance, whether the agency convincingly established that
changes in the project sufficiently reduced it to a minimum." 230
U.S.App.D.C., at 356, 717 F.2d, at 1413.
Footnote 5 Save Our Ten
Acres v. Kreger,
472 F.2d
463, 466 (CA5 1973).
Footnote 6 Foundation for
North American Wild Sheep v. United States Dept. of Agriculture,
supra, at 1177, n. 24 (CA9 1982); see also Wyoming Outdoor
Coordinating Council v. Butz,
484 F.2d
1244, 1249 (CA10 1973).
Footnote 7 Providence Road
Community Assn. v. EPA,
683 F.2d
80, 82 (CA4 1982).
Footnote 8 Hanly v.
Kleindienst,
471 F.2d
823, 829-830 (CA2 1972), cert. denied, 412 U.S. 908 (1973). See
also First National Bank of Chicago v. Richardson,
484 F.2d
1369, 1381 (CA7 1973).
Footnote 9 Cf. Providence
Road Community Assn., supra, at 82, n. 3.
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