County of Maui v. Hawaii Wildlife Fund
In brief
The Court set a permit rule for direct discharges and their functional equivalents, wiped out the Ninth Circuit's ruling (vacated it), and sent the case back (remanded it) without deciding Maui's final permit obligation.
- Where it stands
- Decided
Decided 6-3 · April 23, 2020 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court said the Clean Water Act requires a permit when pollution from Maui County’s wastewater facility, a specific point source, reaches protected waters through groundwater if that route is essentially the same as a direct discharge.
- Who it affects
- The rule gives courts a way to judge pollution that travels indirectly from a specific source to covered waters. The Ninth Circuit must apply it to Maui's wells, so whether Maui ultimately needs a permit remains unresolved.
Summary: written with AI from the case record.
What it's about
It wiped out the Ninth Circuit’s judgment and sent the case back to apply that test (vacated and remanded), without deciding whether Maui actually needed a permit.
The case tested how the Clean Water Act applies when pollution starts at a specific source but reaches covered waters through groundwater.
Question presented
Whether the CWA requires a permit when pollutants originate from a point source but are conveyed to navigable waters by a nonpoint source, such as groundwater.
What the Court decided
Holding
The statutory provisions at issue require a permit when there is a direct discharge from a point source into navigable waters or when there is the functional equivalent of a direct discharge . 886 F. 3d 737, vacated and remanded.
- Result
- Vacated
The vote
From the opinions
“Based on the statutory text and structure, I would hold that a permit is required only when a point source discharges pollutants directly into navigable waters.”
What's next
The case returns to the Ninth Circuit, which must apply the Supreme Court's standard to Maui County's wells. Whether Maui ultimately needs a permit remains unresolved.
Documents
Docket activity
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AI analysis generated: Impact Analysis
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More questions
- What did Maui v. Hawaii Wildlife Fund decide?
- The Court said permits are required for direct discharges from point sources into navigable waters and their functional equivalents.
- Did the Supreme Court uphold the Ninth Circuit's ruling?
- No. It wiped out that ruling (vacated it) and sent the case back (remanded it) for further proceedings.
- What role did groundwater play in Maui v. Hawaii Wildlife Fund?
- Maui County pumped treated wastewater into underground wells; pollutants then traveled through groundwater to the Pacific Ocean. That raised whether the Clean Water Act covered this indirect path.
- What happens next for Maui County?
- The case returns to the Ninth Circuit, which must apply the Supreme Court's standard to Maui's wells. Whether Maui ultimately needs a permit remains unresolved.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.