Petition for Writ of Certiorari — Crutchfield v. United States Army Corps of Engineers

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< Ye-t80. JUL 2 4 2003

Supreme Court of the Anited States

FRANCES BROADDUS CRUTCHFIELD

and

HENRY RUFFIN BROADDUS,

Petitioners,

Vv.

UNITED STATES ARMY CORPS OF ENGINEERS

and

COUNTY OF HANOVER, VIRGINIA,

Respondents.

On Petition for Writ of Certiorari

to the United States Court of Appeals

for the Fourth Circuit

Petition for Writ of Certiorari

William B. Ellis

1406 Confederate Avenue

Richmond, Virginia 23227

(804) 355-4043

Counsel of Record for Petitioners

LANTAGNE LEGAL PRINTING

801 East Main Street Suite 100 Richmond, Virginia 23219 (800) 847-0477

(4 PV

ae

QUESTION PRESENTED

Whether a court, having previously set aside an

administrative determination as arbitrary and unreasonable,

may apply “heightened scrutiny” when reviewing the

agency’s decision reaching the same result following

remand?

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PARTIES TO THE PROCEEDING

The parties to this proceeding are as follows:

Petitioners:

Respondents:

Frances Broaddus Crutchfield, an individual,

and her son, Henry Ruffin Broaddus, an

individual.

United States Army Corps of Engineers, an

agency of the United States of America, and

the County of Hanover, Virginia, a local

government within the Commonwealth of

Virginia.

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TABLE OF CONTENTS

SPRPEPEPIPEN PUMEUDOIEN EEE? bic ccs ce sescenessssenes

PAR ibe 10 THE PROCEEDING ... 0... ces ecceees

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OPINION BELOW ..... eos ee ere Te Tee eee Te

th ) te be. eT eE TT Tee OCT Tee Te

STATUTORY PROVISIONS INVOLVED ...........

ie eg se Bt” oy ) Eee nr

REASONS FOR GRANTING THE PETITION .......

I. THIS COURT SHOULD RESOLVE THE

CONFLICT AMONG THE CIRCUITS AS

TO WHETHER “HEIGHTENED SCRUTINY”

OF ADMINISTRATIVE ACTION

FOLLOWING REMAND IS APPROPRIATE

oF re ee ee

II. WHETHER “HEIGHTENED SCRUTINY” IS

APPROPRIATE AND PERMISSIBLE IS AN

IMPORTANT QUESTION ARISING UNDER

THE ADMINISTRATIVE PROCEDURE ACT

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TABLE OF AUTHORITIES

CASES

Cape May Greene, Inc. v. Warren, 698 F.2d 179 (3rd

Coe. FONE ask nbenee¥kandaubaseeraaesbees 12

Chevron U.S.A. Inc. v. NRDC, 467 U.S. 837 (1984) .... 13

Citizens to Preserve Overton Park v. Volpe, 401 U.S.

Oe RUPEES ok beans Ko acd Soman b er eeadene ix os 13

City of Los Angeles v. U.S. Dept. of Transportation,

560 FO 01s a Ge BONE 6s Se ctnccesenes -1]

Crutchfield v. U.S. Army Corps of Engineers, 154

F. Supp. 2d 878 (E.D. Va. 2001) .......... 1,4, 5

Crutchfield v. U.S. Army Corps of Engineers, 214

F. Supp. 2d 593 (E.D. Va. 2002) ........ ie ee

Crutchfield v. County of Hanover, 325 F.3d 211

(4th Cir., Mare 27, 2003) occ cc iccesess 2, 35, 8,9

Dow Chemical Co. v. U.S. Environmental Protection

Agency, 605 F.2d 673 (3rd Cir. 1979) .......... 12

Food Marketing Institute v. ICC, 587 F.2d 1285

SE 6s oi Wed cepedeuans aeueuunen 1]

Greyhound Corp. v. Interstate Commerce Comm'n,

GEG Fae Bore es CO URED wks es coe ednes 1]

Maggard v. O’Connell, 671 F.2d 568 (D.C. Cir. 1982) .. 11

Motor Vehicle Mfrs. Ass’n of the United States, Inc.

v. State Farm Mut. Auto. Ins. Co., 463 U.S.

PL e ) ) ne ananEa rani Mere nnen caret Ror Rami ron 13

Natural Res. Def. Council, Inc. v. SEC, 606 F.2d

pees Se. Gs SOU hb 4 00s 000 ee ees 11,12

Preston v. Heckler, 734 F.2d 1359 (9th Cir. 1984) ...... 12

STATUTES

Administrative Procedure Act

Sk me et ere rrr her” & 13

Clean Water Act

Generally, 33 U.S.C. §§ 1251, et seg. ........... 5

Section 404, 33 U.S.C. § 1344 .............. 1,3

Judicial Code and Judiciary

SOUR A GIAO) oid csieeesieer tee 2

REGULATORY MATERIALS

Department of Defense, Corps of Engineers

Permit Rules:

Ki gae fF Bh oe eeePreer eT reer ere 4

° Vi «

Nationwide Permit Rules:

33 CFR, $390 (2002) ois isessivesecceess:

S3CPR. 63903 COU oc cicecccicccsnuveas 3

33 CFR. § 330.4 (2002) ......cccceceeesceees 3 |

33 CFR. § 330.6 (2002) ..........eeeeee. 3,6,7 :

56 Fed. Reg. 59,110, 59,117 (Nov. 22, 1991) ..... 6 |

The Nationwide Permits:

65 Fed. Reg. 12,818, 12,898 (Mar. 9, 2000) ...... 6

CAE NCR SE pan Dirt (TPs

67 Fed. Reg. 2020 (Jan. 15,2002) ....... 1, 3, 4, 6

Environmental Protection Agency

Section 404(b)(1) Guidelines

SOUP R. § EPATe coscicniccsweeviveseens 3,4

ee euoy eae Hers aes:

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OPINIONS BELOW

This case concerns a second determination by the

United States Army Corps of Engineers (“the Corps”) that

certain discharges of fill material proposed by the County of

Hanover, Virginia (“the County”) are authorized by various

general “nationwide permits” issued by the Corps by

regulation pursuant to Section 404 of the Clean Water Act,

33 U.S.C. § 1344. See generally, 33 C.F.R. § 330 (2002)

(the Corps’ nationwide permit rules); 67 Fed. Reg. 2020

(Jan. 15, 2002) (the nationwide permits themselves). The

discharges proposed by the County are associated with

construction of a planned sewage treatment project.

The Corps first determined that discharges associated

with the project were authorized by nationwide permits on

June 7, 2000. That action was set aside by the United States

District Court for the Eastern District of Virginia on August

14, 2001. Crutchfield v. U.S. Army Corps of Engineers, 154

F. Supp. 2d 878 (E.D. Va. 2001) (“Crutchfield P’), Appendix

at 260A. The district court found that the Corps’ use of the

summary “nationwide permit” process was “remarkably

illogical” and a “belated contrivance of expediency”

designed to avoid more stringent regulatory scrutiny of the

project. /d. at 897-98, Appendix at 294A-298A. The United

States Court of Appeals for the Fourth Circuit dismissed the

Corps’ and the County’s appeal from the district court’s

original decision on May 31, 2002.

On remand, and despite assurances by the Corps to

the district court and the parties that it would apply the more

stringent criteria of the individual permit process to the

County’s project, the Corps again authorized the discharges

associated with the County’s proposal on the grounds that

they were covered by nationwide permits. See Memorandum

=

for the Record, Appendix at 152A. The district court, after

reviewing the Corps’ action on remand in light of its prior

conduct, giving “heightened scrutiny” to the administrative

record, set aside the Corps’ action for a second time on

August 7, 2002. Crutchfield v. U.S. Army Corps of

Engineers, 214 F. Supp. 2d 593 (E.D. Va. 2002)

(“Crutchfield IT’), Appendix at 27A.

On appeal, the United States Court of Appeals for the

Fourth Circuit reversed. Crutchfield v. County of Hanover,

325 F.3d 211 (4th Cir., March 27, 2003), Appendix at 1A.

The panel determined that the prior administrative history

was irrelevant and that the district court was not permitted to

apply “heightened scrutiny” to the Corps’ action reaching the

same result following remand.

JURISDICTION

The Fourth Circuit filed its decision on March 27,

2003, and entered an order denying petitioner’s motion for

rehearing on April 25, 2002. Appendix at 256A. This Court

has jurisdiction to review the circuit court’s decision on a

writ of certiorari pursuant to 28 U.S.C. § 1254(1).

STATUTORY PROVISION INVOLVED

5 U.S.C. § 706(2)

The Administrative Procedure Act requires federal

courts to “hold unlawful and set aside agency action,

findings, and conclusions found to be . . . arbitrary,

capricious, an abuse of discretion, or otherwise not in

accordance with law.” Appendix at 259A.

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STATEMENT OF FACTS

Petitioners brought this and a prior case to challenge

use by the Corps of a summary permit procedure (called

“Nationwide Permits ’ or “NWPs”) to authorize discharges of

fill associated with construction of the County’s proposed

Totopotomoy Sewage Treatment Plant. NWPs are general

permits issued by regulation and are intended to apply only to

projects with minimal environmental effects. 33 C.F.R.

§ 330.1 (b) and (c) (2002). Ifa project involves discharges

of dredged or fill material to one-half acre of wetlands or

more, then the Corps’ rules require use of a full, individual

permit process rather than NWPs. 67 Fed. Reg. 2020, 2085

(NWP 39 is subject to one-half acre maximum), 2092

(Condition 15, restricting impacts when multiple NWPs are

used). Ifa project is eligible for NWPs, the applicant need

not perform an evaluation of off-site alternatives (i.e.,

alternatives at other locations), nor demonstrate that it is the

least environmentally damaging of those alternatives. 33

C.F.R. § 330.4, 330.6 (2002). Ifa project requires an

individual permit, then the applicant must perform such an

evaluation and make such a demonstration to obtain a

permit.'

' To obtain an individual permit, a project must

comply with regulations published by the Environmental

Protection Agency (“EPA”). See Clean Water Act

§ 404(b)(1), 33 U.S.C. § 1344(b)(1). Those regulations

require the applicant to demonstrate that no less

environmentally-damaging alternative to the project is

available. 40 C.F.R. § 230.10 (2002). The applicant must

also overcome a regulatory presumption that less

environmentally damaging alternatives exist to discharging

fill material into wetlands in the case of projects that do not

e

Before one may use and rely upon certain NWPs

(including NWP 39 which is at issue in this case), one must

provide the Corps with “pre-construction notification” of the

proposed discharges and obtain verification from the Corps

that they qualify for the NWPs. The Corps’ verification may

either be express and in writing (as occurred in this case), or

it may be inferred by the passage of forty-five days without

objection from the Corps. See, e.g., 67 Fed. Reg. 2020,

2085, 2090 (Jan. 15, 2002) (regarding NWP 39 and

Condition 13).

On June 7, 2000, the Corps determined that the :

County’s project qualified for three NWPs, authorizing the

County to discharge dredged or fill material during

construction of the proposed sewage treatment plant, a

discharge forcemain that would convey treated sewage away

from that plant, and an outfall structure and diffuser that

would discharge the treated effluent into the Pamunkey

River. Crutchfield I, 154 F. Supp. 2d at 891, Appendix at

283A. Although additional, much more extensive discharges

of dredged or fill material were also contemplated by the

County in association with construction of facilities to

convey raw sewage to the proposed plant for treatment

require proximity to water. 40 C.F.R. § 230.10(a)(3) (2002).

The applicant must rigorously evaluate all reasonable

alternatives, including not engaging in the proposed activity

at all (“no action alternative”), 40 C.F.R. § 230.10(a)(1)(i)

(2002), and engaging in alternate activities in different

locations (“off site alternatives”), 40 C.F.R.

§ 230.10(a)(1)(ii) (2002). Finally, the project must satisfy

other environmental criteria such as not causing or

contributing to the violation of water quality standards, 40

C.F.R. § 230.10(b); 33 C.F.R. § 320.4 (2002).

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(called the Totopotomoy Creek Interceptor Sewer, or “TC

Interceptor’), those discharges were not included by the

County in its NWP verification request. If considered part of

the same project, those discharges would have caused the

total wetland impacts of the project greatly to exceed one-

half acre, and therefore would have compelled an individual

permit review process. The Corps determined that the

treatment plant, discharge forcemain, and outfall structure

and diffuser were a separate and complete project, which had

“independent utility” apart from any means of conveying raw

sewage to the plant for treatment.

Petitioners brought an action against the Corps and

the County on August 8, 2000, seeking to invalidate the

NWP verifications. Their purpose was to obtain an

individual permit review of the County’s proposal, including

the required assessment of potential off-site alternatives. See

generally, Crutchfield I, Appendix at 260A. On August 14,

2001, the district court found that the Corps’ determination

was arbitrary and capricious. The NWP verifications

therefore were set aside as contrary to the Clean Water Act,

33 U.S.C. §§ 1251 et seg. See Crutchfield I, 154 F. Supp. 2d

at 903, Appendix at 307A. The County’s appeal from the

district court’s decision was dismissed by the Fourth Circuit

on May 31, 2002. Crutchfield et al. v. County of Hanover,

Virginia, Record No. 01-2488 (4th Cir., filed May 31, 2002).

Following the district court’s decision and while its

appeal in the Fourth Circuit was pending, the County filed a

new individual permit application with the Corps on

November 16, 2001. This time, the County included in its

application a means for delivering some sewage to the

proposed sewage treatment plant (through a facility known as

the Lee Davis Road Pump Station and Forcemain).

sé

The Lee Davis Road Pump Station and Forcemain

was not contained in the County’s previous application to the

Corps, nor was it contained in any of the County’s

wastewater facilities planning documents. Further, none of

the means for delivering wastewater to the proposed

treatment plant that were included in the County’s

wastewater facilities planning documents were included in

the new individual permit application.

Petitioners filed timely comments with the Corps

objecting to the issuance of the permit. Among other

objections, those comments contended that the Lee Davis

Road Pump Station and Forcemain was a pretext and a sham

that could not accomplish either the short- or long-term goals

previously stated by the County. Petitioners argued it was

designed to obtain expeditious authorization from the Corps

so the County could proceed to construct the sewage

treatment plant, but was not the “complete” project which

applicants are required to disclose and permit. 33 C.F.R.

§ 330.6(c) (2002).

To be “complete,” the activities proposed must by

themselves have “independent utility.” 56 Fed. Reg. 59,110,

59,117 (Nov. 22, 1991). According to the Corps, the

dispositive factor in deciding if a set of activities has

“independent utility” is whether the project as proposed

“would be constructed absent the construction of other

projects in the project area.” 67 Fed. Reg. 2020-01, 2094

(Jan. 15, 2002) (emphasis added); see also 65 Fed. Reg.

12,818, 12,898 (Mar. 9, 2000). In other words, the proposed

activities must be “fully justified” even if the Corps were not

to approve any other activities. 33 C.F.R. § 330.6(d) (2002)

(emphasis added).

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Petitioners contended that if the Corps were to

consider the other facilities the record suggested actually

were planned by the County to deliver wastewater to the

sewage treatment plant -- one of which was already under

construction for the County by a developer -- the impacts of

the overall project would exceed the threshold of one-half

acre of wetlands and would require use of the individual

permit process. That, in turn, would require the County to

evaluate off-site alternatives to its project and to demonstrate

its proposal was least environmentally-damaging alternative

before it could obtain a permit. Petitioners contended that no

such demonstration had been, or could be, made.

Notwithstanding the petitioners’ comments, and

despite assurances given by the Corps to the district court

and the parties that it would use the individual permit process

to evaluate the County’s project, on April 4, 2002, the Corps

announced its decision once again to verify application of

NWPs to the project and to terminate the individual permit

process. Appendix at 152A.

On April 19, 2002, petitioners filed this action,

alleging that the Corps’ verification of NWPs for the project

was improper because the Corps did not articulate a rational

basis for concluding that the project, as proposed, constituted

a single and complete project. Crutchfield I, 214 F. Supp.

2d at 602-03, Appendix at 38A. In subsequent briefing, the

parties agreed that the dispositive question before the Corps

was whether the project as proposed would be constructed

absent the construction of other projects in the project area.

On August 7, 2002, the district court issued its

decision, which included a detailed examination of the

administrative record. It found that the Corps had

completely failed to address the dispositive question.

“=

Crutchfield IT, 214 F. Supp.2d at 652, Appendix at 144A-

146A. Because the Corps had failed to address the

dispositive question, the district court found the record

contained no articulated agency rationale to which it could

defer. See id. at 652-53, Appendix at 145A-148A.

Accordingly, it set aside the Corps’ determination that the

project was “complete.”

The County filed a notice of appeal on August 20,

2002, and the Corps filed one on October 2, 2002. On March

27, 2003, a panel of the United States Court of Appeals for

the Fourth Circuit reversed. Crutchfield v. County of

Hanover, 325 F.3d 211, Appendix at 1A. The panel found

the district court erred by applying “heightened scrutiny” to

the administrative record:

Despite acknowledging the governing

caselaw, the district court in this case declined

to accord the necessary deference to the Army

Corps’ decision. Noting that the Corps’ initial

decision had been overturned as arbitrary and

capricious, the district court asserted that the

Corps’ review of the second project had

reached "virtually the same decision after

judicial remand." 214 F. Supp. 2d 593, 621

(citing Natural Res. Def. Council, Inc. v. SEC,

606 F.2d 1031, 1049 n. 23 (D.C.Cir. 1979)).

It therefore decided that the Corps’ most

recent decision should be assessed under

"heightened scrutiny" and proceeded to

engage in a highly exacting, essentially de

novo examination of the record, repeatedly

rejecting the Corps’ conclusions and drawing

its own independent inferences from the

evidence. /d.

ute

This was an erroneous approach that

turned the Administrative Procedure Act on

its head.”

The panel opinion notes that the Corps assigned new staff to

the project and generated a voluminous record. However, it

does not cite any evidence in that record of consideration by

the Corps of the dispositive question: whether the County

would in fact construct ihe project as proposed absent the

construction of other means for conveying wastewater to the

sewage treatment plant.

? Crutchfield v. County of Hanover, 325 F.3d at 218,

Appendix at 12A. The district court in fact did not draw its

own independent inferences from the evidence. The court

determined only that the Corps had failed to address the

evidence before it in a meaningful way and had failed to

explain the reasons underlying its determinations.

Crutchfield II, 214 F. Supp. 2d at 652-53, Appendix at 145A-

149A.

«16.

REASONS FOR GRANTING THE PETITION

1. THIS COURT SHOULD RESOLVE THE

CONFLICT AMONG THE CIRCUITS AS

TO WHETHER “AEIGHTENED

SCRUTINY” OG: ADMINISTRATIVE

ACTION FOLLOWING REMAND IS

APPROPRIATE AND PERMISSIBLE.

With this decision, the United States Circuit Courts

of Appeals are in conflict as to whether “heightened

scrutiny” of administrative action following remand is

appropriate and permissible under the Administrative

Procedure Act.

The District of Columbia Circuit has determined that

“heightened scrutiny” can be appropriate and is permitted.

More exacting scrutiny will be particularly

useful when for some reason the presumption

of agency regularity, see Citizens to Preserve

Overton Park, supra, 401 U.S. at 415, 91

S.Ct. 814, is rebutted, as where the agency has

demonstrated undue bias towards particular

private interests, see, e.g., Central Florida

Enterprises, Inc. v. FCC, 194 U.S.App.D.C.

118, 598 F.2d 37 (1978); where the agency

has had a history of “ad hoc and inconsistent

judgments” on a particular question, Local

777 v. NLRB, 195 U.S.App.D.C. 280 at 287-

289, 603 F.2d 862 at 869-871 (1978); where

the agency has arrived at an identical result

after remand from a reviewing court for

further explanation of reasons, e.g., Food

Marketing Inst. v. ICC, 190 U.S.App.D.C.

- 82

388, 392-93, 587 F.2d 1285, 1289-90 (1978);

accord, Citizens to Preserve Overton Park,

supra, 401 U.S. at 420, 91 S.Ct. 814; or when

an agency has departed from its consistent and

longstanding precedents or policies, see Office

of Communication of United Church of Christ

v. CAB, 191 U.S.App.D.C. 360 at 366-367,

590 F.2d 1062 at 1068-1069 (1978);

International Union v. NLRB, 148

U.S.App.D.C. 305, 317-18, 459 F.2d 1329,

1341-42 (1972).

Natural Res. Def. Council, Inc. v. SEC, 606 F.2d 1031, 1049

n. 23 (D.C. Cir. 1979). See also, Maggard v. O’Connell, 671

F.2d 568, 570-71 (D.C. Cir. 1982) (Judicial review must be

“contextually tailored” and courts may apply “more exacting

scrutiny” or “greater care” when “danger signals” suggest an

agency may not really have taken a “hard look” at the salient

problems) and Greyhound Corp. v. Interstate Commerce

Comm’n, 668 F.2d 1354, 1358 (D.C. Cir. 1981) (“A

reviewing court . . . will accord a somewhat greater degree of

scrutiny to an order that arrives at substantially the same

conclusion as an order previously remanded by the same

court,” citing Food Marketing Institute v. ICC, 587 F.2d

1285, 1289-90 (D.C. Cir. 1978)).’

> But c.f, City of Los Angeles v. U.S. Dept. of

Transportation, 165 F.3d 972, 977-78 (D.C. Cir. 1999) (“The

City submits that our review should be more strict given that

the Department arrived at the same result on remand as it had

reached in its initial decision, but that proposition strikes us

as flatly inconsistent with the Chenery doctrine. See SEC v.

Chenery Corp. (Cheney I), 318 U.S. 80, 87 L. Ed. 626, 63 S.

Ct. 454 (1943); SEC v. Chenery Corp. (Chenery II), 332

9?

The Ninth Circuit also has determined that

heightened scrutiny of agency action can be appropriate.

More exacting scrutiny [of agency action is]

particularly useful when for some reason the

presumption of agency regularity . . . is

rebutted.

Preston v. Heckler, 734 F.2d 1359, 1372 (9th Cir. 1984)

(quoting Natural Res. Def. Council, Inc. v. SEC, supra.).

The Third Circuit also appears to follow this rule.

[T]he scope of judicial review [of agency

action under the arbitrary and capricious test]

necessarily admits of some flexibility and the

stringency of our inquiry will depend on, and

often vary according to, the variety of factors

presented by a particular case.

Cape May Greene, Inc. v. Warren, 698 F.2d 179, 190 (3rd

Cir. 1983). See also Dow Chemical Co. v. U.S.

Environmental Protection Agency, 605 F.2d 673, 681-82

(3rd Cir. 1979).

Thus the Fourth Circuit, in determining that

“heightened scrutiny” of administrative action following

remand is “an erroneous approach,” is in conflict with other

circuits that have considered this issue.

U.S. 194, 200, 91 L. Ed. 1995, 67 S. Ct. 1575 (1947)”).

Pas.

Granting the writ of certiorari is appropriate in this

case to assure uniformity among the Circuits in reviewing

administrative actions.

Il. WHETHER “HEIGHTENED SCRUTINY”

IS APPROPRIATE AND PERMISSIBLE IS

AN IMPORTANT QUESTION ARISING

UNDER THE ADMINISTRATIVE

PROCEDURE ACT.

The Administrative Procedure Act requires federal

courts to “hold unlawful and set aside agency action,

findings, and conclusions found to be . . . arbitrary,

capricious, an abuse of discretion, or otherwise not in

accordance with law.” 5 U.S.C. § 706(2). The statute does

not address the degree of deference to be accorded by the

federal courts to administrative determinations.

This Court, of course, has addressed the general

subject on many occasions. See, e.g., Chevron U.S.A. Inc. v.

NRDC, 467 U.S. 837 (1984); Motor Vehicle Mfrs. Ass'n of

the United States, Inc. v. State Farm Mut. Auto. Ins. Co., 463

U.S. 29, 43 (1983); Citizens to Preserve Overton Park v.

Volpe, 401 U.S. 402, 415 (1971). However, it has never

determined whether the deference normally accorded to

agency fact-finding may be reduced when an agency has

previously acted arbitrarily or unreasonably with respect to a

particular matter.

This case presents an important question of

administrative law. Are the federal courts required to be

endlessly credulous of agency findings and conclusions, as

the Fourth Circuit decided? Or, may a reviewing court

consider the agency’s prior behavior in the same matter in

+

determining the appropriate degree of scrutiny to be given to

the agency’s fact-finding?

CONCLUSION

The Court should grant the petition for a writ of

certiorari to resolve a conflict among the Courts of Appeals

concerning an important question of federal administrative

law.

Respectfully submitted,

Vy) oe

WILLIAM B. ELLIS

Counsel of Record for Petitioner

1406 Confederate Avenue

Richmond, Virginia 23227

(804) 355-4043