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Keywords

lawsuitplaintiffstatutejudicial reviewendangered species actwater rights
jurisdictionregulationjudicial reviewendangered species actwater rights

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Bennett v. Spear

Facts

The Klamath Project, a federal irrigation scheme, was operated by the Bureau of Reclamation and affected two endangered fish species. In 1992, the Bureau notified the FWS that the project might impact the Lost River Sucker and Shortnose Sucker. Following a formal consultation, the FWS issued a Biological Opinion concluding that the project's operation was likely to jeopardize the fish's existence. The irrigation districts, which relied on the project for water, filed a lawsuit against the FWS and the Secretary of the Interior, claiming that the FWS's actions violated the Endangered Species Act and the Administrative Procedure Act.

The Klamath Project, one of the oldest federal reclamation schemes, is a series of lakes, rivers, dams and irrigation canals in northern California and southern Oregon. The project was undertaken by the Secretary of the Interior pursuant to the Reclamation Act of 1902, 32 Stat. 388, as amended, 43 U.S.C. 371 et seq., and the Act of Feb. 9, 1905, 33 Stat. 714, and is administered by the Bureau of Reclamation, which is under the Secretary's jurisdiction. In 1992, the Bureau notified the Service that operation of the project might affect the Lost River Sucker (Deltistes luxatus) and Shortnose Sucker (Chasmistes brevirostris), species of fish that were listed as endangered in 1988, see 53 Fed. Reg. 27130 -27133 (1988).

Issue

Whether the petitioners have standing to seek judicial review of the biological opinion under the citizen-suit provision of the Endangered Species Act and the Administrative Procedure Act.

Whether the petitioners, who have competing economic and other interests in Klamath Project water, have standing to seek judicial review of the biological opinion under the citizen-suit provision of the ESA, 1540(g)(1), and the Administrative Procedure Act (APA), 80 Stat. 392, as amended, 5 U.S.C. 701 et seq.

Rule

The Endangered Species Act requires federal agencies to ensure that their actions do not jeopardize endangered species or their critical habitats. The 'zone of interests' test determines whether a plaintiff's interests are protected by the statute under which they seek relief.

The ESA requires the Secretary of the Interior to promulgate regulations listing those species of animals that are 'threatened' or 'endangered' under specified criteria, and [*158] to designate their 'critical habitat.' 16 U.S.C. 1533. The ESA further requires each federal agency to 'insure that any action authorized, funded, or carried out by such agency . . . is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species which is determined by the Secretary . . . to be critical.' 1536(a)(2).

Analysis

The Supreme Court found that the irrigation districts' claims fell within the zone of interests protected by the Endangered Species Act. The Court reasoned that the districts had sufficiently alleged facts to establish standing, as their economic interests in the water supply were directly affected by the FWS's biological opinion. The Court emphasized that the 'zone of interests' test should not be interpreted too narrowly, allowing for a broader interpretation of who may seek judicial review.

The Supreme Court found that the irrigation districts' claims fell within the zone of interests protected by the Endangered Species Act. The Court reasoned that the districts had sufficiently alleged facts to establish standing, as their economic interests in the water supply were directly affected by the FWS's biological opinion. The Court emphasized that the 'zone of interests' test should not be interpreted too narrowly, allowing for a broader interpretation of who may seek judicial review.

Conclusion

The Supreme Court reversed the Ninth Circuit's decision, holding that the irrigation districts had standing to challenge the FWS's biological opinion and remanded the case for further proceedings.

The Supreme Court reversed the Ninth Circuit's decision, holding that the irrigation districts had standing to challenge the FWS's biological opinion and remanded the case for further proceedings.

Who won?

The petitioners, the irrigation districts, prevailed because the Supreme Court determined they had standing to challenge the FWS's biological opinion, which was crucial for their water rights.

The petitioners, the irrigation districts, prevailed because the Supreme Court determined they had standing to challenge the FWS's biological opinion, which was crucial for their water rights.

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