Monsanto Co. v. Geertson Seed Farms: Irreparable Injury to the National Environmental Policy Act?

Authors

Madeline Gwyn

Abstract

The Supreme Court recently embarked on a path toward removing the only teeth the National Environmental Policy Act (NEPA) has--its procedural mandates. In Winter v. Natural Resources Defense Council, Inc. and, more recently, in the controversial case Monsanto Co. v. Geertson Seed Farms, the Court declined to issue an injunction against federal agency action despite the agency's failure to complete an Environmental Impact Statement (EIS) regarding the action, as required by NEPA.

Recommended Citation

Madeline Gwyn, Monsanto Co. v. Geertson Seed Farms: Irreparable Injury to the National Environmental Policy Act?, 61 Emory L. J. 349 (2011).
Available at: https://scholarlycommons.law.emory.edu/elj/vol61/iss2/3