Little Rock Downtown Neighborhood Association, Inc. v. Federal Highway Administration

The federal district court for the Eastern District of Arkansas declined to enjoin a highway reconstruction and widening project. The court found that the plaintiffs—who asserted, among other things, that the defendants failed to consider the project’s cumulative impacts on greenhouse gas emissions—had not shown a likelihood that they would prevail on the merits. The court also found that the plaintiffs did not demonstrate they would suffer irreparable harm if work on the project commenced and that the balance of equities and public interest favored the defendants.

A motion for a preliminary injunction to halt construction of a “gargantuan” highway project in central Arkansas included an argument that the defendants failed to consider the project’s cumulative effects on greenhouse gas emissions when combined with past, present, and reasonably foreseeable emissions of greenhouse gases in the region. The plaintiffs argued that the defendants unreasonably, arbitrarily, and capriciously limited the universe of actions against which it measured cumulative impacts.