Rapanos v. United States, 547 U.S. 715 (2006)
Primary Holding
The 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.
In the case of Rapanos v. United States, the Supreme Court decided that the federal government has limited authority to regulate certain bodies of water under the Clean Water Act. This matters because it means that not all wetlands and smaller water bodies are protected, which can affect how landowners use their property. For consumers, this ruling can impact their rights regarding property development and environmental protections, especially if they own land near these types of water bodies. If someone is planning to develop land or work near water, they should be aware of this ruling, as it may influence what permits they need or whether they face federal regulations.
AI-generated plain-language summary to help you understand this case
In April 1989, John A. Rapanos, the petitioner, filled wetlands on a 54-acre parcel of land in Michigan that he owned and intended to develop. The land had soil conditions that were sometimes saturated, and the nearest navigable water body was located 11 to 20 miles away. Prior to this action, federal regulators informed Rapanos that the saturated areas constituted "waters of the United States" under the Clean Water Act, which prohibited filling these areas without a permit. This led to a protracted legal battle spanning twelve years, involving both criminal and civil litigation against Rapanos. The case reached the Supreme Court after Rapanos and another petitioner, June Carabell, challenged the jurisdiction of the U.S. Army Corps of Engineers regarding their wetlands. The legal dispute was escalated through the federal court system, culminating in a writ of certiorari to the Supreme Court from the United States Court of Appeals for the Sixth Circuit. The case was formally argued before the Supreme Court, which issued its judgment on June 19, 2006. The background context of the case highlights the significant expansion of federal regulatory authority over land use under the Clean Water Act, which has occurred without any amendments to the statute itself. Over the past three decades, the Corps and the Environmental Protection Agency (EPA) have interpreted their jurisdiction to encompass vast areas of swampy land across the United States, asserting control over regions that include intermittent waterways and even areas that may only be covered by water infrequently. This regulatory framework has led to substantial burdens on landowners, including lengthy permit application processes and the potential for severe penalties for non-compliance.
Whether the Clean Water Act's definition of "waters of the United States" extends to wetlands that are not adjacent to navigable waters and do not have a continuous surface connection to such waters.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- February 21, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
S. D. Warren Co. v. Maine Bd. of Environmental Protection, 547 U.S. 370 (2006)
Consumer WonOperating a dam to produce hydroelectricity may result in a discharge into navigable waters, thus requiring state certification under §401 of the Clean Water Act to ensure compliance with water protection laws.
Orff v. United States, 545 U.S. 596 (2005)
Consumer LostCongress 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.
Mid-Con Freight Systems, Inc. v. Michigan Pub. Serv. Comm'n, 545 U.S. 440 (2005)
Consumer LostThe federal statute regarding interstate commerce pre-empts state registration requirements only if they impose an unreasonable burden, and the Michigan law imposing a $100 annual fee on trucks operating entirely in interstate commerce does not constitute such a burden, thus it is not pre-empted by federal law.
Whitman v. Department of Transportation, 547 U.S. 512 (2006)
Mixed OutcomeThe Court held that the jurisdiction of federal courts to review employment-related claims of federal employees is not conferred by 5 U.S.C. §7121(a)(1), but such jurisdiction is not divested by the Civil Service Reform Act (CSRA), allowing for potential claims to be pursued under 28 U.S.C. §1331 if they arise under the Constitution or federal law.