## Facts

- New York City and HUD planned redevelopment of Manhattan’s West Side Urban Renewal Area (WSURA) beginning in 1962, initially providing a 70% middle-income and 30% low-income housing mix.
- In 1969, local agencies amended the plan to convert a designated middle-income site into a 160-unit high-rise low-income housing project; HUD approved the redesignation in December 1972.
- A nearby institution sued to enjoin construction, and individual residents and a neighborhood group intervened as plaintiffs; a neighborhood council and government entities participated as defendants.
- The dispute centered on compliance with the National Environmental Policy Act of 1969 (NEPA), particularly whether HUD sufficiently considered environmental consequences and reasonable alternatives to the chosen site.
- After an initial remand from the court of appeals, HUD issued a “Special Environmental Clearance” that acknowledged potential “social environmental impacts” from the site choice but concluded they were not unacceptable.
- HUD stated that relocating the project would delay construction by about two years and treated that delay as an overriding reason to keep the existing location.

## Issues

1. Whether, after an agency has satisfied NEPA’s procedural duties to consider environmental consequences and alternatives, a reviewing court may require the agency to give determinative weight to particular environmental concerns.
2. Whether a court may forbid an agency from treating non-environmental considerations (such as project delay) as overriding in the agency’s final decision under NEPA.

## Decision

- The Supreme Court reversed the court of appeals.
- The Court held that once an agency decision is subject to and compliant with NEPA’s procedural requirements, judicial review is limited to ensuring the agency considered environmental consequences.
- The Court concluded HUD considered environmental consequences and alternatives for the low-income housing site, and NEPA required no more.
- The court of appeals erred by effectively rebalancing HUD’s decisionmaking, including by disallowing delay as an overriding factor and pressing for an outcome that avoided concentrating low-income housing at the selected site.

## Legal Principles

- NEPA is primarily procedural; it requires agencies to consider environmental impacts and reasonable alternatives, not to reach any particular substantive environmental result.
- Courts reviewing NEPA compliance may ensure the agency took the required “hard look,” but may not substitute judicial judgment for the agency’s policy choice once the procedural obligation is met.
- NEPA does not require agencies to give environmental considerations priority over other appropriate factors; the weighing of competing considerations is committed to agency discretion when the statutory process has been followed.

## Conclusion

The Court ruled that HUD’s documented consideration of environmental consequences and alternatives satisfied NEPA, and that courts may not use NEPA to dictate how an agency balances environmental concerns against other factors or to force a different substantive outcome.


Strycker's Bay Neighborhood Council, Inc. v. Karlen, 444 U.S. 223 (1980)