Document Type

Article

Publication Date

12-1-1988

Abstract

The Supreme Court recently held that a citizen plaintiff must make a good-faith allegation of an ongoing violation in order to bring an enforcement action under the Clean Water Act. The decision in Gwaltney of Smithfield, Ltd. v. Chesapeake Bay Foundation, Inc., will prevent citizens from bringing suit for the assessment of civil penalties solely for past violations of the Clean Water Act.

Publication Title

Land Use and Environmental Law

Volume

4

First Page

143

Comments

Casenote: Gwaltney of Smithfield, Ltd. v. Chesapeake Bay Foundation, Inc.,_ U.S._, 108 S. Ct. 376 (1987).

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