One lawsuit that has been widely recognized as one of the earliest environmental cases is "Scenic Hudson Preservation Conference v. Federal Power Commission," decided in 1965 by the Second Circuit Court of Appeals, prior to passage of the major federal environmental statutes. The case helped halt the construction of a power plant on Storm King Mountain in New York State. The case has been described as giving birth to environmental litigation and helping create the legal doctrine of standing to bring environmental claims. The Scenic Hudson case also is said to have helped inspire the passage of the National Environmental Policy Act (NEPA), and the creation of such environmental advocacy groups as the Natural Resources Defense Council.