Coleman v. Conservation Society of Southern Vermont, Inc.

How later courts describe this case

• fees in actions under the Voting Rights Act of 1964 are to be measured by same standards as in other complex litigation
• vacated and remanded for consideration of effect of statutory amendments on issue of preparation of environmental impact statement
• use of subjective criteria in awarding promotions relevant to the establishment of prima facie case of discrimination
• discussion of the implications of gaps between the assumptions and the characteristics of the data as a recurring problem
• remanded to consider whether court’s judgment ground on fourteenth amendment, state constitutional provisions, or both
• in light of Pub.L. No. 94-83 and Aberdeen & Rockfish Railroad v. SCRAP, 422 U.S. 289, 95 S.Ct. 2336, 45 L.Ed.2d 191 (1975)
• “... it remains within the discretion of a district court to decline an injunction, even where deviations from prescribed NEPA procedures have occurred.”
• remanded to consider whether judgment based upon federal or state constitutional grounds, or both