Bennett v. Spear

520 U.S. 154 (1997)
Decided March 19, 1997
Justice Scalia delivered the opinion of the Court

Case Background

This case involved a challenge to a biological opinion issued by the Fish and Wildlife Service regarding the Klamath Irrigation Project's impact on endangered fish species. Two Oregon irrigation districts challenged water level restrictions imposed to protect endangered sucker fish in Clear Lake and Gerber reservoirs.

Key Legal Questions

Do petitioners have standing under the Endangered Species Act's citizen suit provision?
Can petitioners seek judicial review of the biological opinion?

Supreme Court Holding

The Supreme Court:

Found petitioners have standing
Reversed the Court of Appeals' dismissal
Remanded the case for further proceedings

Court's Reasoning

The Court emphasized that:

The ESA's "any person" language broadly allows judicial review
Petitioners' economic interests are "arguably within the zone of interests" protected by the statute
The biological opinion has "direct and appreciable legal consequences"

Legal Significance

This decision significantly expanded interpretations of standing and judicial review in environmental law, particularly for parties with economic interests in environmental regulations. It established that parties economically affected by environmental agency actions can challenge those actions in federal court, even when their interests may conflict with the environmental protection goals of the statute.

Impact on Environmental Law

Bennett v. Spear broadened access to federal courts for judicial review of environmental agency decisions, allowing regulated parties and those economically impacted by environmental regulations to challenge agency actions more readily.