Psychological health damage as an environmental effect: Metropolitan Edison Co. v. People Against Nuclear Energy

The Supreme court took a narrow view of the term environmental in Metropolitan Edison Co. v. People Against Nuclear Energy when it stated that the purpose of the National Environmental Policy Act (NEPA) is to protect the physical environment. Psychological health damage caused by the perception of the risk of a nuclear accident is not an environmental effect cognizable under NEPA unless their is a demonstrable relationship. Litigants seeking the protection of NEPA must carefully examine the origin and nature of alleged psychological harms and frame their complains to establish a close relationship between a change in the physical environment and the alleged psychological harm