Strycker's Bay Neighborhood Council, Inc. v. Karlen
444 U.S. 223 (1980)

  • The US Department of Housing and Urban Development (HUD) approved a project to build low-income housing in Manhattan.  A local citizen group, Stryker's Bay, opposed the project and sued.
    • Stryker's Bay argued that HUD had not properly considered environmental impacts of the project as they were required to under the National Environmental Policy Act (NEPA).
  • The Trial Court found for HUD. Stryker's Bay appealed.
    • The Trial Court found that HUD's decision-making process was adequate.
  • The Appellate Court reversed and remanded back to HUD.
    • The Appellate Court found that NEPA required consideration of alternatives to the project.
  • HUD prepared a lengthy report asserting that they had considered all of the relevant factors and still found that the project was not unacceptable. Stryker's Bay sued again.
    • The main reason HUD found the project to be acceptable was that relocating the project would result in "unacceptable delay."
  • The Trial Court found for HUD. Stryker's Bay appealed.
    • The Trial Court found that HUD had properly and in good faith considered the alternatives and environmental impacts of the project, thereby meeting their requirements under NEPA.
  • The Appellate Court reversed.  HUD appealed.
    • The Appellate Court found that "unacceptable delay" was a capricious reason for finding the project acceptable.  Instead, the Appellate Court suggested that HUD actually consider environmental factors.
  • The US Supreme Court reversed the Appellate Court and found HUDs assessment to be acceptable.
    • The US Supreme Court found that NEPA requires "a fully informed and well-considered decision" but not necessarily "a decision the judges of the Appellate Court would have reached had they been members of the decision-making process."
      • Basically, as long as the agency considers the environmental consequences of the project, NEPA is satisfied.  There are no specific rules on how an agency should weigh the factors influencing their decision.
  • In a dissent it was argued that the Court has a role in determining whether the decision was "arbitrary or capricious," and if so, they had a responsibility to overturn it.
    • What if after considering the environmental impacts, an agency decided to permit a project solely because they thought the people who opposed it were all dirty hippies?  Would the Court feel they were empowered to overturn the decision?