Environmental Defense Fund, Inc. v. Alexander

The federal government (defendant), through the Army Corps of Engineers, developed a plan to construct and finance a waterway. The plan originally called for a width of 170 feet at the bottom of the channel and was authorized by Congress in 1946. However, Congress did not grant any funds for the project at the time. In 1966, another study was done by the Corps, which recommended that the waterway be constructed with a width of 300 feet at the bottom of the channel. In 1967, the Environmental Defense Fund (plaintiff) and other organizations testified in opposition to the project. Congress appropriated funds in 1971 and 1972 to begin construction of the waterway, with the 300-foot channel width. Also in 1971, the Environmental Defense Fund and another organization filed a lawsuit to try to stop the construction. That lawsuit was dismissed. Construction actually began in 1972, and the Environmental Defense Fund sued again in 1976 regarding the environmental impact of the waterway. In 1978, the complaint was amended to add an allegation, made for the first time, that the Corps did not have the authority to widen the channel from what Congress initially authorized. The Corps did not seek immediate injunctive relief. When the lawsuit was filed in 1976, the Corps had expended $36 million related to the project, and the Corps had expended approximately $604 million by the time the complaint was amended in 1978. The district court determined that the claims were barred by the equitable doctrine of laches and dismissed the case. The Environmental Defense Fund appealed.