Quimbee logo
DMCA.com Protection Status
From our private database of 18,800+ case briefs...

Train v. Colorado Public Interest Research Group, Inc.

United States Supreme Court
426 U.S. 1 (1976)

Train v. Colorado Public Interest Research Group, Inc.


In 1946, Congress enacted the Atomic Energy Act (AEA), 42 U.S.C. § 2011 et seq, to regulate the production of nuclear energy. The Atomic Energy Commission (AEC) administered the AEA by, among other things, creating standards for the discharge of radioactive materials into waterways. Congress later enacted the Federal Water Pollution Control Act (FWPCA), 33 U.S.C. § 1251 et seq, to regulate water pollution, including pollution from radioactive materials. The Environmental Protection Agency (EPA) administered the FWPCA through a permit program. Only permit holders were legally permitted to discharge pollutants into waterways. EPA Administrator Russell Train (defendant) excluded from the permit program any radioactive materials already reached by the AEA’s regulatory scheme. The Colorado Public Interest Research Group, Inc., together with other environmental groups and citizens (plaintiffs), brought suit against Train, seeking an injunction directing the EPA to include in its permit program all radioactive materials discharged into waterways. The district court held that the AEC had exclusive authority to regulate radioactive materials covered by the AEA. The court of appeals reversed in favor of the plaintiffs, finding that the text of the FWPCA defined “pollutant” as including radioactive materials and provided no exceptions. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Marshall, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 498,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 498,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial