Case Law Details
Metropolitan Edison Company v. People Against Nuclear Energy
Project Description:
The Metropolitan Edison Company proposed to restart the Three Mile Island nuclear reactor that had been damaged in a serious breakdown.
460 U.S. 766
460 U.S. 766
U.S. Supreme Court
04/19/1983
Three Mile Island Nuclear Plant Restart
Other
Case Summary
The plaintiffs challenged a decision by the Nuclear Regulatory Commission (NRC) to allow the Three Mile Island reactor to resume operations. Plaintiffs charged that the environmental impact statement prepared by the NRC was inadequate because it failed to consider the psychological damage to persons living in the vicinity of the facility as well as the damage to the stability, cohesiveness and well-being of communities in the neighborhood. The court of appeals agreed with plaintiffs’ contentions and ordered NRC to prepare a new EIS considering those impacts. The Supreme Court granted NRC’s petition for certiorari and reversed the decision of the court of appeals.
Key Holdings
NEPA
Scope of Environmental Impacts. The Supreme Court found that NEPA is limited to analysis of environmental impacts to the physical environment. NEPA does not require analysis of impacts that do not have a “reasonably close causal relationship between a change in the physical environment and the effect at issue.” The Court compared the concept of “reasonably close causal relationship” to the concept of “proximate cause from tort law.” The Court found that the “risk” of a new accident at the facility is not an effect on the physical environment. The Court concluded that NEPA “does not require agencies to evaluate the effects of risk, qua risk.”
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