ELR Citation: 55 ELR 20146
No(s). 24-14171 (11th Cir. Oct 20, 2025)

In an unpublished opinion, the Eleventh Circuit affirmed summary judgment for the Army Corps of Engineers in a challenge to its issuance of a letter of permission for construction of a private dock project on the Georgia coast. An environmental group argued the letter violated the Cumberland Island National Seashore Act and that the Corps' failure to prepare an EIS violated NEPA. A district court concluded the letter was not arbitrary and capricious, and granted summary judgment for the Corps. The appellate court found the Corps reasonably concluded the dock would be "minor in nature" based on its size, scale, and other attributes; that the project would not have a significant impact on environmental values because construction would take less than a year and involved no fill material, dredging, or excavation; and that the project would face no appreciable opposition. It affirmed summary judgment for the Corps.