## Facts

- A coalition and individual Black residents sued to stop an extension of Interstate 670 from downtown Columbus to the airport.
- The planned route passed through older central-city neighborhoods with high concentrations of racial minorities and would displace many residents; plaintiffs asserted that roughly 75% of displaced persons were minorities.
- Planning was conducted by regional, state, and local transportation entities under federally required public-involvement procedures, including an “Action Plan.”
- Public input was primarily channeled through a Citizens’ Advisory Committee that plaintiffs argued was dominated by business and government representatives and insufficiently included residents of the most affected neighborhoods.
- Plaintiffs contended the process limited meaningful public input by treating the freeway decision as settled and inviting comment mainly on secondary matters.
- The agencies held public informational meetings, circulated newsletters and written materials, and evaluated multiple options, including a “no-build” alternative and different alignments.
- Plaintiffs proposed alternative transportation options and a different alignment; a restudy considered these alternatives but did not adopt them.
- The administrative record reflected comparative analysis of alignments, including an alternative the court described as having a substantially greater impact on racial minorities than the chosen route.
- Plaintiffs sought declaratory and injunctive relief to prevent construction until alleged procedural and civil-rights violations were corrected.

## Issues

1. Whether the public-involvement process for planning and locating the I-670 extension complied with federal regulations implementing the Federal-Aid Highway Act.
2. Whether the planning and routing decisions violated Title VI of the Civil Rights Act of 1964 or its implementing regulations by producing an unjustified disproportionate adverse impact on racial minorities.

## Decision

- The court entered judgment for defendants and denied declaratory and injunctive relief.
- The court concluded the overall public-participation process substantially complied with applicable federal requirements, despite acknowledged imperfections.
- The court held plaintiffs did not prove a Title VI violation based on the record as a whole, including the comparative impacts of feasible alternatives.
- Construction of the I-670 extension was not enjoined.

## Legal Principles

- Judicial review of federally funded transportation planning is limited; courts generally do not substitute policy judgments for agency judgments when required procedures are substantially followed and the record supports the decision.
- Public-participation obligations under federal highway planning regulations are assessed in light of the overall process (meetings, publications, advisory mechanisms, and consideration of alternatives); shortcomings do not automatically require injunctive relief.
- Disproportionate impact on minority communities, standing alone, is insufficient to establish a Title VI violation in highway siting; plaintiffs must show discriminatory intent or failure to reasonably consider less discriminatory alternatives under governing standards.
- When the record shows consideration of minority impacts and feasible alternatives with equal or greater adverse effects, courts are less likely to invalidate the chosen alignment.

## Conclusion

The court declined to halt the I-670 extension because the agencies’ planning process, viewed as a whole, satisfied federal public-participation requirements, and the evidence did not establish unlawful discrimination under Title VI in light of the alternatives analyzed and the comparative impacts reflected in the administrative record.


Coalition of Concerned Citizens Against I-670 v. Damian, 608 F. Supp. 110 (S.D. Ohio 1984)