Environmental Defense Fund v. Lamphier

James Lamphier and his wife (defendants) owned a farm in Virginia. Beginning in 1979, state authorities discovered that Lamphier was disposing of hazardous wastes on his farm as a business. For example, Lamphier had buried drums of solvents on the property, which, when tested, showed a high degree of flammability. The state authorities issued remedial orders. In 1980, federal authorities began investigating whether Lamphier was complying with the Resource Conservation and Recovery Act (RCRA). Lamphier had not obtained a permit under the RCRA to operate a hazardous-waste-disposal site. In 1981, the Environmental Defense Fund (EDF) and the Chesapeake Bay Foundation (CBF) (plaintiffs), which were private entities, sued Lamphier under the citizen-suit provision of the RCRA, alleging violations of the law and seeking civil penalties. The state (plaintiff) intervened and asserted additional claims. During trial proceedings, the EDF and the CBF agreed not to seek civil penalties and to seek only injunctive relief, costs, and attorney fees. The trial court found that Lamphier had created a common-law nuisance and had violated the RCRA. The court then issued an injunction ordering Lamphier to comply with applicable hazardous-waste regulations and to provide governmental authorities with access to the farm for purposes of monitoring compliance. Lamphier appealed, arguing that the district court was not authorized to issue an injunction and that there had been no showing of irreparable harm to support the issuance of an injunction.