444 U.S. 223, 100 S. Ct. 497, 62 L. Ed. 2d 433 (1980) (per curiam)
Strycker's Bay Neighborhood Council v. Karlen is a cornerstone in the Supreme Court's articulation of the National Environmental Policy Act's (NEPA) role in federal decision-making.
Does NEPA require a federal agency to elevate environmental concerns over other appropriate policy considerations when making decisions, and may a reviewing court direct an agency to reorder its priorities after the agency has taken a hard look at environmental consequences?
NEPA Section 102(2)(C) requires federal agencies to take a hard look at the environmental consequences of proposed actions by preparing a detailed statement addressing environmental impacts, adverse effects, and alternatives, and to consider that information in the decision-making process. NEPA is essentially procedural; it does not mandate particular substantive outcomes or require selection of the most environmentally protective alternative. Under the APA, courts review agency compliance to ensure procedures were followed and that the ultimate decision is not arbitrary or capricious; courts may not substitute their judgment for that of the agency or require agencies to elevate environmental factors above other statutorily permissible considerations.
No. NEPA does not require agencies to elevate environmental concerns over other considerations. Once an agency has adequately considered environmental consequences, a reviewing court may not interject its own substantive judgment or direct the agency to give environmental factors paramount importance. The Supreme Court reversed the Second Circuit.
Strycker's Bay is a leading case confirming that NEPA is procedural rather than substantive. It is frequently paired with Vermont Yankee to illustrate the limits of judicial power to reshape agency procedures or compel particular outcomes under NEPA. For law students, the case cements the concepts of hard-look review and arbitrary-and-capricious review, clarifies that NEPA does not impose a least-environmental-harm alternative requirement, and highlights the deference courts owe to agencies' reasoned balancing of environmental and non-environmental considerations.