Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402 (1971), is a landmark decision by the Supreme Court of the United States that established the basic legal framework for judicial review of the actions of administrative agencies.
[1] During the Interstate Highway System building boom of the late 1950s and early 1960s, public parks were viewed as desirable construction sites because approval did not require invocation of eminent domain.
The Court held that the Secretary's decision did not fall into the Administrative Procedure Act (APA)'s Section 701(a)(2) exception from judicial review for action "committed to agency discretion.
[7] Justice Thurgood Marshall, writing for the Court, held § 4(f) "is a plain and explicit bar to the use of federal funds for construction of highways through parks; only the most unusual situations are exempted."
[6] Because the costs of building through parks were demonstrably low, as construction before 1966 had shown, the Court held that the 1966 enactment of the "feasible and prudent" clause "indicates that protection of parkland was to be given paramount importance.
[7] Its conclusion that courts must examine the entire record of an agency's decision established the "hard look" doctrine further expanded upon by State Farm Mutual Automobile Insurance Co. v. Campbell (1983).