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Administrative Law Keyed to Lawson
Friends of the Earth, Inc. v. Laidlaw Environmental Services, Inc.
Citation:
528 U.S. 167 (2000)Facts
Laidlaw Environmental Services operated a hazardous waste incinerator facility in Roebuck, South Carolina, which discharged treated wastewater into the North Tyger River. Although Laidlaw had a permit under the National Pollutant Discharge Elimination System (NPDES), it repeatedly violated the permit’s mercury discharge limits. After Laidlaw failed to comply despite a state enforcement action, several environmental organizations filed a citizen suit under the Clean Water Act, alleging ongoing violations and seeking declaratory and injunctive relief, civil penalties, and attorney fees. During the litigation, Laidlaw achieved substantial compliance with its permit requirements and later shut down the facility, leading to the question of whether the case had become moot.
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