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Florida Keys Citizens Coalition, Inc. v. United States Army Corps of Engineers

374 F. Supp. 2d 1116 (2005)

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Florida Keys Citizens Coalition, Inc. v. United States Army Corps of Engineers

United States District Court for the Southern District of Florida
374 F. Supp. 2d 1116 (2005)

  • Written by Liz Nakamura, JD

Facts

The Federal Highway Administration (FHWA) (defendant) approved a highway safety improvement project for Highway 1 in the Florida Keys. FHWA segmented the project into two pieces: (1) replacement of the Jewfish Creek bridge, and (2) roadway safety improvements. The roadway safety improvements were approved pursuant to a categorical exclusion under the National Environmental Protection Act (NEPA) for roadway safety improvements that do not increase traffic capacity. The bridge replacement was approved after the submission of an environmental-impact statement (EIS). In addition, FHWA produced extensive documentation as to the cumulative impacts of the entire road safety project. The existing bridge was over 60 years old, structurally unsound, and posed an identifiable safety issue. The Florida Keys Citizens Coalition (FKCC) (plaintiff) sued, arguing the bridge-replacement project had been improperly segmented from related projects and thereby improperly limited the scope of the EIS and irrevocably committed the FHWA to funding future, related projects.

Rule of Law

Issue

Holding and Reasoning (Huck, J.)

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