ELR Citation: 56 ELR 20058
No(s). 25-12873 (11th Cir. Apr 21, 2026)

The Eleventh Circuit, 2-1, vacated a district court ruling that preliminarily enjoined further construction on a facility constructed by the state of Florida in the Everglades to assist in immigration enforcement. Environmental groups and the Miccosukee Tribe sued state and federal officials for failing to conduct an environmental review under NEPA. The district court issued a preliminary injunction, finding construction of the facility was a final agency action under the APA and a "major federal action" under NEPA. The appellate court found the district court erred by entering the injunction because plaintiffs failed to prove either a final agency action or federal control, and that the injunction violated a provision of the Illegal Immigration Reform and Immigrant Responsibility Act that prohibited district courts from enjoining immigration enforcement. It vacated and remanded for further proceedings.