## Facts

- West Virginia highway officials planned an interstate highway segment through Charleston that would displace low-income Black residents living in a neighborhood known as the Triangle.
- In 1966–1967, the State obtained federal right-of-way approvals from the U.S. Secretary of Transportation for the project.
- In 1968, Congress amended the Federal-Aid Highway Act to bar approval of federally aided highway projects displacing persons unless the Secretary received “satisfactory assurances” from the State that adequate replacement housing would be available within a reasonable period before displacement.
- The statutory assurances contemplated availability of “decent, safe, and sanitary” dwellings, equal in number to displaced households and reasonably accessible to employment.
- After the amendments, “satisfactory assurances” were implemented through DOT regulations and practice requiring a comprehensive relocation plan and review at key project-approval stages, including before construction approval.
- Triangle residents and the Triangle Improvement Council contended the State had not submitted a formal relocation plan and that adequate affordable housing would not be available when displacement occurred.

## Issues

1. Whether plaintiffs were entitled to injunctive and declaratory relief requiring submission and federal review of a comprehensive relocation plan before federal construction approval for the project.
2. Whether intervening DOT regulations and governmental assurances applying the 1968 relocation requirements to ongoing projects rendered the dispute moot.

## Decision

- The Fourth Circuit affirmed the denial of relief.
- The court affirmed on mootness grounds rather than the district court’s conclusion that the 1968 requirements did not apply to projects with pre-1968 right-of-way approvals.
- The court relied on intervening DOT regulatory action and federal and state representations indicating that relocation planning and compliance with the 1968 requirements would be required before construction approval.
- Because the plaintiffs sought to prevent construction approval absent adequate relocation protections, and the agencies’ post-suit position indicated those protections would be implemented, the court found no live controversy requiring judicial relief.

## Legal Principles

- A federal court lacks authority to grant declaratory or injunctive relief when intervening events eliminate a live dispute and the requested relief has effectively been obtained through subsequent governmental action.
- Post-filing regulatory changes and authoritative agency representations about future compliance can moot a challenge to anticipated governmental conduct.
- The 1968 Federal-Aid Highway Act conditions federal approval of displacement-causing highway projects on the Secretary’s receipt of satisfactory assurances of adequate relocation housing, implemented through DOT regulation and administrative review.

## Conclusion

The Fourth Circuit declined to reach the merits of whether the 1968 relocation-planning regime applied as a matter of law to the Charleston project, holding instead that intervening DOT regulations and assurances of compliance eliminated any present need for judicial intervention and made the case moot.


Triangle Improvement Council v. Ritchie, 429 F.2d 423 (4th Cir. 1970)