Seneca Meadows, Inc. v. Town of Seneca Falls

The New York Court of Appeals ruled that Seneca Meadows, Inc. (SMI)—the owner and operator of a major landfill in the Town of Seneca Falls—had standing to assert a State Environmental Quality Review Act (SEQRA) claim challenging a 2016 local law that would have prohibited the landfill’s operation after December 31, 2025. The Court of Appeals reversed a 3-2 decision by the New York Appellate Division concluding that SMI lacked standing because it failed to establish it would suffer an environmental injury. (The Town Board was not defending the law, but a nonprofit corporation and an individual member and officer of the organization pressed the argument that SMI lacked standing.) The Court of Appeals agreed with SMI that it had standing under 1989 and 1996 Court of Appeals precedents that held that an owner of property subject to a proposed action does not need to allege an environmental injury to have standing for a SEQRA claim. The Court of Appeals called it “obvious” that SMI had standing based on application of these precedents, writing that “[j]ust as both the landowner whose commercial development would be blocked by the rezoning in Har and the property owner whose intended mining operations would be prohibited by the zoning ordinance in Gernatt had standing to challenge the respective defendant’s compliance with SEQRA simply due to their status as impacted property owners, SMI also has standing based solely on its ownership of the land subject to the 2016 Law.” The Court of Appeals declined to review a statute of limitations raised by the nonprofit corporation and individual respondent, “as the parties will litigate the merits of the SEQRA claim to a final determination on remittal.”