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Train v. Colorado Pub. Int. Research Group, Inc.

(1976)

Supreme Court of the United States - 426 U.S. 1

tl;dr:

The Federal Water Pollution Control Act does not give the Environmental Protection Agency the power to regulate nuclear waste because nuclear waste is not a “pollutant” within the intended purpose of the Act.

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ICRAIssue, Conclusion, Rule, Analysis for Train v. Colorado Pub. Int. Research Group, Inc.

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Facts & HoldingTrain v. Colorado Pub. Int. Research Group, Inc. case brief facts & holding

Facts:Congress enacted the Federal Water Pollution Control Act (FWPCA) to...

Holding:Holding (Marshall): The plain text of the Federal Water Pollution...

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Train v. Colorado Pub. Int. Research Group, Inc. | Case Brief DeepDive
Majority opinion, author: Me. Chief Justice Burger
Level 1
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The case involves whether the establishment of Devil's Hole as a national monument granted federal water rights in unappropriated water. The National Park Service protested against the Cappaerts' application for permits to change the use of water from their wells under Nevada law, as their pumping was causing the water level in Devil's Hole to decrease and affecting the Devil's Hole pupfish. The United States filed a complaint seeking an injunction to limit the Cappaerts' pumping from specific wells and locations near Devil's Hole, alleging that the United States reserved the unappropriated waters for the requirements and purposes of the reservation. The District Court issued a preliminary injunction limiting pumping from specific wells to return the water level of Devil's Hole to no more than 3.0 feet below the marker. The court found that regulating the pumping could stabilize the water level at Devil's Hole and that failure to issue the injunction would result in irreparable injury to the United States, as there was a grave danger that the Devil's Hole pupfish may be destroyed. The District Court ruled that the President reserved unappropriated waters necessary for the purpose of preserving Devil's Hole as a national monument, which included the preservation of the pool and the pupfish in it. The court found that the federal water rights predated those of the Cappaerts and that the United States was not estopped. The court also determined that the public interest required granting the injunction. The District Court issued a final decree that permanently enjoined pumping that would lower the water level below the 3.0-foot level.

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