Whether the Obama Presidential Center project constitutes a major federal action under environmental laws when roadwork is federally funded, and whether federal agencies improperly segmented environmental reviews and ignored environmental impacts

QUESTIONS PRESENTED The questions presented are: 1. Whether the Obama Presidential Center project (the “OPC”), which includes four structures constructed over 19.3 acres of Frederick Law Olmsted’s Jackson Park, located next to Lake Michigan, is a major federal action under the federal environmental laws when the roadwork required because of the destruction and alteration of its internal roadwork, necessitated by that construction, is federally funded? 2. Whether a federal court can properly defer to a federal agency’s narrow, unsupported and highly deferential definition of a major project escapes review under this Court’s recent decision in Loper Bright v. Riamondo (2024) and its well-established decision in Citizens to Preserve Overton Park, Inc. v. Volpe (1971)? 3. Whether the federal reviews of the OPC relied upon below employed illegal segmentation to allow large portions of the undertaking to escape federal review under the NEPA, the Transportation Act and other federal statutes, which conflicts with the established interpretive principles used in the D.C. Circuit? 4. Whether the Seventh Circuit erred in deferring to the federal agencies who either ignored or belittled the destruction of hundreds of trees, migratory bird habitats, and other u key environmental in declining to require an environmental impact statement? 5. Whether the Seventh Circuit erred in affirming the trial court’s denial of the Plaintiffs’ only motion for leave to amend pursuant to Fed. R. Civ. P. 15, which was filed before any discovery began, before any schedule was set, and before any trial date was set? 6. Whether the Seventh Circuit’s refusal to reverse the Rule 12(b)(6) dismissal of state law claims for violation of the public trust doctrine and improper delegation violated both Illinois law and this Court’s precedents dealing with the duty of loyalty, the duty of care, and the nondelegation doctrine under the public trust doctrine?