Druid Hills Civic Association, Inc. v. Federal Highway Administration

The Presidential Parkway was a proposed highway that would run through the Olmsted Park network in Atlanta’s Druid Hills Historic District. The Federal Highway Administration (highway administration) (defendant) was the lead agency for the Presidential Parkway project and circulated a draft environmental-impact statement for comment. The section of the statement addressing § 4(f) of the Department of Transportation Act discussed alternatives to the Presidential Parkway. In particular, the Decatur Parkway plan and Moreland Avenue plan proposed alternative routes that also used parklands and historic districts to some degree. The Department of the Interior (DOI) commented on the statement draft, noting that the discussion of alternatives in the draft was inadequate and failed to sufficiently address § 4(f) considerations. The United States Department of Transportation also provided comments and said that the draft statement adequately addressed the effects of the project and measures to minimize harm. Subsequently, the highway administration approved the final environmental-impact statement. The DOI decided that the final statement did not satisfactorily respond to the DOI’s comments, and thus it objected to § 4(f) approval of the project. The statement did not address the quantity or nature of harm that the alternative routes would cause to parks or historic sites. The highway administration, acting through a designee of the secretary of the United States Department of Transportation (secretary), approved the project, and the Druid Hills Civic Association (Druid) (plaintiff) filed a motion in federal district court to enjoin construction of the project. The district court denied the motion. Druid appealed, asserting that the highway administration did not comply with the requirements of § 4(f).