Monsanto Co. v. Geertson Seed Farms: Irreparable Injury to the National Environmental Policy Act?

The Supreme Court recently embarked on a path toward removing the only teeth the National Environmental Policy Act (NEPA) has--its procedural mandates. In Winter v. Natural Resources Defense Council, Inc. and, more recently, in the controversial case Monsanto Co. v. Geertson Seed Farms, the Court declined to issue an injunction against federal agency action despite the agency\u27s failure to complete an Environmental Impact Statement (EIS) regarding the action, as required by NEPA