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FHWA corridor approval for this ABCD highway in 1966,~ and had begun acquiring property under the "hardship" procedures, no relocation assurances had been submitted to the FHWA. Even though no federal funds had yet been expended on the project, the court held: IF]or the purpose of applying the various federal statutes and regula- tions, a federal-aid project is any project for which the state has obtained location approval. The court issued an injunction barring further acquisition of property pending state compliance with the federal relocation acts. This requirement, the court pointed out, was consistent with Congress' intent, expressed in the UP~, that federal controls must be exercised over all projects in which the FHWA m~ht participate. Designating a project "federal" only at the time of federal expenditure or design approval would leave large numbers o~ highway displacees excluded from the protections of the URA. The £a Raza Unida opinion may have a broad effect. Under it, the congres- sional mandate of the relocation acts will be applied to cr~y road on which federal funds might be expended. Once federal route approval has been obtained, state highway departments will henceforth ignore the URA at their peril. IV. Courts and Remedies Satisfactory assurances are an essential element of a successful reloca- tion program, and of full compliance with the UPA. But apparent non-compliance with the URA's provisions has caused some urban displacees to seek enforcement of such assurances in the courts. In several cases, relief has been denied because of judicial hesitancy to halt displacements pending adjudication of the merits of the case. Two cases illustrate the necessity for stays pending appeal in highway relocation lawsuits. In both Triangle Improvement Co.ail ~ ~itchie and Concerned Citizens for the Preservation o f Clarksv~lle ~ Volpe, minority displacees sought the benefits of the 1968 Highway Act--assurances that they would be relocated in dwellings which were decent, safe and sanitary. The plaintiffs sought to enjoin their displacement until relocation assurances were prepared. Disagreeing with the plaintiffs' contentions on the merits, the lower courts denied the requested relief. The district and appellate courts, however, refused to issue stays pending appeal, and as a result, the plaintiffs' displacement proceeded during the pendency of their appeal. Ultimately, the appellate courts found the cases moot, because the displacees, as noted in one case, were "beyond the pale of whatever benefit proper assurances would have afforded." The appellate courts never reached the merits of these cases because of their reluctance to halt relocation during the appeal. As these cases suggest, the courts must intervene decisively and promptly in the relocation process, or judicial safeguards will serve little purpose. Denial of injunctive relief is likely to render the case moot; enforcement of the relocation assurances becomes difficult; and any later victory for the plaintiffs is a paper one. III-10