PPL Montana, LLC v. Montana
United States Supreme Court
565 U.S. 576 (2012)
- Written by Charles McCurdy, JD
Facts
PPL Montana, LLC (PPL) (plaintiff) owned and operated hydroelectric dams on three rivers in Montana, including several dams along the Great Falls reach of the Missouri River. PPL paid rent to the United States to use the riverbeds under these facilities. The Great Falls reach had several significant waterfalls, and Lewis and Clark’s expedition had to use portages to get around those waterfalls. PPL brought suit in trial court, seeking a declaratory judgment that the State of Montana (defendant) did not own the riverbeds under the hydroelectric dams. Montana counterclaimed, arguing that the state owned the riverbeds under the equal-footing doctrine. The trial court granted summary judgment to Montana, ordering PPL to pay $41 million in compensation for using the riverbeds between 2000 and 2007. The Montana Supreme Court affirmed, concluding that under a short-interruptions analysis, the limited breaks in navigability and current recreational uses of the Missouri River meant that the river was navigable and that the state had gained title to the riverbeds when it achieved statehood in 1889. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Kennedy, J.)
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