Dept. of Transportation v. Public Citizen
541 U.S. 752 (2004)
- The Federal Motor Carrier Safety Administration (FMCSA)
planned to lift the ban on Mexican trucking companies operating in the US.
- FMCSA issued new regulations as to safety and inspection
- FMCSA prepared an Environmental Assessment (EA), but they
did not prepare and Environmental Impact Statement (EIS) as possibly
required by the National Environmental Protection Act (NEPA).
- The EA focused mainly on the environmental impact from
doing more inspections, not on the impact from more trucks driving the
- Public Citizen sued to stop the regulations until an EIS
- Public Citizen argued that the increased number of trucks
on US roads was liable to have a significant environmental impact, and
therefore an EIS was required.
- The Trial Court found for FMCSA. Public Citizen appealed.
- The Trial Court found that although the FMCSA regulations
resulted in more trucks, FMCSA did not have control over those trucks and
therefore did not have to account for them in an EIS.
- The Appellate Court reversed. FMCSA appealed.
- The Appellate Court found that the EA was deficient
because it failed to give adequate consideration to the overall
environmental impact from the Mexican trucks.
- In a unanimous decision, the US Supreme Court reversed the
Appellate Court and allowed the regulations to be approved without
requiring an EIS.
- The US Supreme Court held that the FMCSA had no control
of the trucks once the regulations were passed, and would therefore be
unable to act on the findings of an EIS even if it did conduct one.
- FMCSA has no statutory authority to impose or enforce
emissions controls or to establish environmental requirements unrelated
to motor carrier safety.
- The Court also found that the passage of the regulations
was not sufficiently responsible for the increased pollution caused by
the trucks to warrant an EIS.