California v. Sierra Club

The California Water Project utilized a system of dams, storage facilities, and canals to transport water from northern California to central and southern California. The existing system stored water behind dams on the Sacramento River. When needed, water would be released into the Sacramento–San Joaquin Delta. The water would then be pumped from the delta and transported south by the California Aqueduct. However, when released into the delta, the water would mix with infiltrating salt water from the Pacific Ocean, which would degrade the water’s quality. To improve water quality, the state of California (defendant) sought to construct a 42-mile canal to bypass the delta. The Sierra Club (plaintiff) joined two private citizens to enjoin the canal’s construction under the Rivers and Harbors Appropriation Act of 1899, which prohibits obstruction of navigable waterways unless authorized by Congress. The Sierra Club argued that the act required consent of the Army Corps of Engineers to construct the canal. California argued that the act did not provide a private right of action. The United States District Court for the Northern District of California held that the act created a private remedy. California appealed. The Court of Appeals for the Ninth Circuit affirmed. California appealed. The United States Supreme Court granted certiorari.