T-Mobile South, LLC v. City of Roswell, 135 S. Ct. 808

Background

T‑Mobile applied in Feb 2010 to build a 108‑foot "monopine" cell tower on residentially zoned land in Roswell, GA; the Planning & Zoning Division recommended approval with conditions.
At a public City Council hearing on Apr 12, 2010, council members voiced aesthetic, height, and compatibility concerns and unanimously voted to deny the application.
Two days later the City sent T‑Mobile a one‑sentence written denial letter that merely stated the denial and informed T‑Mobile it could obtain the meeting minutes from the city clerk.
The detailed written minutes explaining council members’ statements were not approved and published until May 10, 2010 — 26 days after the denial letter and four days before T‑Mobile’s 30‑day window to file suit expired.
T‑Mobile sued under 47 U.S.C. § 332(c)(7)(B)(iii), arguing the City failed to provide a written decision stating reasons supported by substantial evidence; district court ruled for T‑Mobile, Eleventh Circuit reversed, Supreme Court granted certiorari.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 332(c)(7)(B)(iii) requires localities to provide written reasons when denying wireless siting applications	T‑Mobile: the statute’s "substantial evidence" standard imports administrative‑law reason‑giving; localities must state reasons in writing	Roswell: the statute only requires a written denial and a written record supporting it; no separate reason‑giving obligation	Yes — localities must provide written reasons for denials (but reasons need not be elaborate)
Whether the written reasons must appear in the denial letter/notice itself	T‑Mobile: denial should include the reasons in the same written decision to enable review	Roswell: reasons may be in the written record separate from the denial; no requirement they appear in the denial letter	No — reasons need not appear in the denial itself; they may be in another written record
Timing: when must the written reasons be provided relative to the denial and the 30‑day suit window	T‑Mobile: reasons must be provided promptly so applicant can decide to sue	Roswell: suit window should run from the written denial; reasons can follow	Reasons must be provided or made available essentially contemporaneously with the written denial (so applicant can meaningfully decide to pursue expedited review)
Effect of City's conduct here (sufficiency of Roswell's compliance)	T‑Mobile: Roswell failed to provide reasons contemporaneously	Roswell: it issued a written denial and preserved a written record; minutes were available before suit deadline	City did not comply — detailed minutes (containing reasons) were published 26 days after denial, not essentially contemporaneously; Supreme Court remanded for further proceedings on remedy and other issues

Key Cases Cited

Rancho Palos Verdes v. Abrams, 544 U.S. 113 (1995) (discusses limits of local authority under the Telecommunications Act)
United States v. Carlo Bianchi & Co., 373 U.S. 709 (1963) (explains "substantial evidence" as a term of art in administrative review)
SEC v. Chenery Corp., 318 U.S. 80 (1943) (requires agencies to disclose grounds of administrative actions for meaningful review)
Motor Vehicle Mfrs. Assn. v. State Farm, 463 U.S. 29 (1983) (agencies must articulate satisfactory explanations for actions)
Beaumont, S.L. W.R. Co. v. United States, 282 U.S. 74 (1930) (necessity of complete statements showing the grounds for administrative determinations)
Bennett v. Spear, 520 U.S. 154 (1997) (defines when agency action is "final")
Bowman Transp., Inc. v. Arkansas‑Best Freight System, 419 U.S. 281 (1974) (courts may uphold imperfectly clear agency decisions if the path is reasonably discernible)
National Assn. of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007) (harmless‑error doctrine applies in administrative law)
Florida Power & Light Co. v. Lorion, 470 U.S. 729 (1985) (courts normally remand administrative errors to the agency)