Sackett v. EPA (2012)

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Sackett v. EPA (2012)
Court Supreme Court of the United States
Citation
Date decided March 21, 2012
Appealed from 9th Circuit
Followed by
Sackett v. EPA (2023)

Facts

The Sacketts owned a huge residential lot in Idaho. They were building their home & filling in holes therein when the U.S. Environmental Protection Agency ("EPA") sent them a compliance order.

The aforesaid order stated that the Sackett property wetlands were subject to the Clean Water Act (CWA) due to their proximity to Priest Lake. The order demanded the Sacketts not fill in the wetlands for home-building or face daily fines of $75,000.

Procedural History

The Sacketts sued the EPA in a federal district court in Idaho.

Issues

Is a compliance order under the Clean Water Act a final agency action entitled to judicial review under the APA (Administrative Procedure Act)?

Arguments

EPA attorneys argued that the Clean Water Act precluded judicial review of the compliance order.

Holding

A compliance order under the Clean Water Act is a final agency action entitled to judicial review under the APA.

Reasons

Antonin Scalia wrote that the APA permits judicial review of final agency actions for which there is no other adequate remedy.

Resources