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CWA Compliance Orders Subject to Pre-Enforcement Review

Apr 04, 2012

In an unprecedented decision published March 21, 2012, the U.S. Supreme Court reversed the Ninth Circuit’s Court of Appeals to unanimously hold an EPA compliance order issued pursuant to the Clean Water Act (“CWA”) as “final agency action for which there is no adequate remedy other than [judicial review under the Administrative Procedure Act (“APA”)].”  Sackett v. Environmental Protection Agency, 2012 WL 932018, at *7 (U.S.).  It further held that the CWA “does not preclude [APA] review.”  Id.  This holding did not go so far as to decide whether EPA’s compliance order is enforceable; with standing now established, the Sacketts will argue that issue on remand.

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