Orff v. United States, 545 U.S. 596 (2005)
Primary Holding
Congress did not waive the United States' sovereign immunity for suits brought by third-party beneficiaries under the Reclamation Reform Act of 1982, and therefore, individuals who are not parties to a government contract cannot sue the United States for breach of that contract.
In the case of Orff v. United States, a group of farmers in California tried to sue the U.S. government because they believed a water contract between the government and their water district was broken, which affected their water supply. The Supreme Court ruled that these farmers, who were not part of the contract, could not sue the government because the law did not allow it. This decision is important for consumers because it clarifies that only parties directly involved in a contract can hold the government accountable for breaches, protecting the government from being sued by unrelated individuals. This case is relevant if someone believes they are affected by a government contract but are not a direct party to it.
AI-generated plain-language summary to help you understand this case
In Orff v. United States, the underlying dispute involved individual farmers and farming entities in California, known as petitioners, who purchased water from the Westlands Water District. The Westlands Water District had a water service contract with the United States Bureau of Reclamation, established in 1963, which stipulated the annual quantities of water to be provided. In 1993, the Bureau reduced the water supply to Westlands, prompting the petitioners to claim that this reduction constituted a breach of contract. Although the petitioners were not direct parties to the contract, they argued that they were intended third-party beneficiaries entitled to enforce it. They also contended that the United States had waived its sovereign immunity regarding breach of contract claims through a provision in the Reclamation Reform Act of 1982. The procedural history of the case began when the petitioners filed a lawsuit in federal district court against the United States, seeking to hold it accountable for the alleged breach of the 1963 contract. The case was subsequently appealed to the United States Court of Appeals for the Ninth Circuit, which ruled against the petitioners. The petitioners then sought a writ of certiorari, leading to the Supreme Court's review of the case. Relevant background context includes the establishment of the Reclamation Act of 1902, which initiated a federal program for water storage and distribution projects in the arid Western States, including California. The Bureau of Reclamation administers the Central Valley Project (CVP), which is responsible for water distribution in California's Central Valley. The reductions in water delivery that sparked the lawsuit were influenced by environmental obligations imposed by the Central Valley Project Improvement Act of 1992, which required the Bureau to comply with the Federal Endangered Species Act and dedicate water for fish and wildlife restoration efforts.
Whether the petitioners, as intended third-party beneficiaries, have the right to sue the United States for breach of contract under the Reclamation Reform Act of 1982, given that they are not parties to the original contract between the United States and Westlands Water District.
The judgment is affirmed.
- Court
- Supreme Court
- Decision Date
- February 23, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Thomas
- Damages Awarded
- N/A
- Data Quality
- high
San Remo Hotel, L. P. v. City and County of San Francisco, 545 U.S. 323 (2005)
Consumer LostFederal courts cannot create an exception to the full faith and credit statute, 28 U.S.C. §1738, for claims brought under the Takings Clause of the Fifth Amendment, thereby affirming that state court decisions on takings claims must be respected in federal court.
John R. Sand & Gravel Co. v. United States, 552 U.S. 130 (2008)
Consumer LostA court must consider the timeliness of a lawsuit filed in the Court of Federal Claims, even if the government waives the issue, due to the special statute of limitations that governs claims in that court.
Rapanos v. United States, 547 U.S. 715 (2006)
Consumer LostThe Supreme Court held that the Clean Water Act's jurisdiction over "waters of the United States" is limited to relatively permanent, standing, or continuously flowing bodies of water, as well as wetlands that have a continuous surface connection to such waters, thereby rejecting the broader interpretation that included intermittent and ephemeral water bodies.
National Assn. of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007)
Consumer LostThe transfer of permitting authority under the Clean Water Act to state authorities does not require compliance with the consultation provisions of the Endangered Species Act, as Section 7(a)(2) of the ESA does not operate as an additional criterion for such transfers.