Mid-States Coalition for Progress v. Surface Transportation Board
United States Court of Appeals for the Eight Circuit
345 F.3d 520 (2003)
- Written by Eric Miller, JD
Facts
The Surface Transportation Board (STB) (defendant), a federal agency, approved a proposal from the Dakota, Minnesota & Eastern Railroad Corporation (DM&E) to construct a new rail line and upgrade existing rail lines to reach coal mines in Wyoming. In accordance with the National Environmental Policy Act (NEPA), the STB prepared an environmental-impact statement (EIS). The Mid-States Coalition for Progress (the coalition), which represented the interests of various landowners who were opposed to the DM&E’s plans for expansion, petitioned the United States Court of Appeals for the Eight Circuit for review of the EIS, arguing that it failed to sufficiently address the long-term effects of the increased availability of coal that would result from the rail expansion. DM&E filed a brief in which it argued that, even if an increased supply of coal were to drive the construction of new power plants, the location of those power plants was not yet known and therefore could not be addressed.
Rule of Law
Issue
Holding and Reasoning (Arnold, J.)
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