Friends of the Everglades, Inc., et al. v. Secretary of the U.S. Department of Homeland Security, et al.

Circuit 11Apr 21, 2026

Split Score

SplitScore: 31/100

Case Summary

Disposition

Vacated

The Eleventh Circuit held that construction of a state-built immigration detention facility in the Florida Everglades was not subject to the National Environmental Policy Act (NEPA) because there was no final federal agency action and the project was not a "major federal action" under the 2023 amendments to NEPA. Concluding that the district court abused its discretion in issuing a preliminary injunction and that part of the injunction also contravened 8 U.S.C. § 1252(f)(1), the court vacated the injunction and remanded.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether the Administrative Procedure Act’s “final agency action” requirement is a jurisdictional limitation on the federal courts’ subject-matter jurisdiction (as the Eleventh Circuit holds) or merely a non-jurisdictional element of a cause of action (as the D.C. Circuit holds).

Circuit Positions

Circuit 11(this circuit)

Final-agency-action requirement is jurisdictional; without it, courts lack subject-matter jurisdiction.

Circuit 0

Final-agency-action requirement is not jurisdictional but goes to the merits of the APA claim.

Conflict Summary

The Eleventh Circuit treats the absence of a final agency action as a jurisdictional bar that deprives federal courts of power to hear the case, whereas the D.C. Circuit views the final-agency-action requirement as non-jurisdictional, affecting only the plaintiff’s ability to state a claim under the APA but not the court’s jurisdiction.

Parties & Counsel

Parties

Appellant:Secretary of the United States Department of Homeland Security
Appellee:Friends of the Everglades, Inc.