The U.S. Supreme court declined to review a decision of the Third Circuit Court of Appeals finding that the New Jersey Department of Environmental Protection (NJDEP) did not violate the Civil Rights Act by permitting a St. Lawrence Cement-operated slag grinding plant to open in Camden, N.J.

A citizen's group had sued the state for granting an operating permit to the plant, claiming that the environmental impact of the operation would result in a disparate impact on the predominantly black residents of Camden. Originally, a U.S. district court judge found that NJDEP had violated the Civil Rights Act and prevented the plant from opening as scheduled, although St. Lawrence was never accused of any violations. The Appeals Court later overturned the trial judge based upon a 2001 Supreme Court case (Alexander v. Sandoval) denying a private cause of action under the cited provision of the Act. The Supreme Court found that the Third Circuit decision was consistent with Sandoval.