Carter v. United States

How later courts describe this case

• concluding that a plan to launder ill-gotten proceeds was one facet of a cocaine distribution scheme
• no EIS required where ministerial granting of mineral patent was not major federal action and did not enable recipient to affect environment
• since Department of the Interior had no discretion to consider environmental factors in issuing a mineral patent, it was a ministerial act and not subject to NEPA
• “the actions taken by the Secretary of the Interior in processing an application for patent by such claimant are not discretionary; issuance of a patent can be compelled by court order”
• "By failing to make a timely motion for the production of the Jencks Act materials as the statute requires, appellants waived any right they may have had to complain on appeal of an alleged lack of governmental production."
• a deadly serious offer to pay a reward to anyone who "kills, maims, or seriously injures a member of the American Nazi Party" at the time of the Nazi march in Skokie five weeks away constitutes solicitation
• non-discretionary acts not subject to NEPA