On February 25, 2016, the United States District for the District of Minnesota granted the Metropolitan Council’s motion to dismiss challenges to a proposed light rail transit route—the Southwest Light Rail Transit (SWLRT) project—that would connect downtown Minneapolis to the southwestern Twin Cities. Opus Woods Conserv. Ass. & SFI Ltd. Partnership v. Metropolitan Council, No. 15-1637 (D. Minn. Feb. 25, 2016). In so doing, the court declined to extend a limited National Environmental Policy Act (“NEPA”) cause of action it had recognized in a 2015 decision, also involving the SWLRT, to the related context of historical property review under Section 4(f) of the Department of Transportation Act of 1966. 49 U.S.C. § 303. Plaintiffs in the case alleged that the Met Council violated NEPA,…