## Facts

- An environmental group and counsel filed suit in federal court naming the “Colorado River Ecosystem” as plaintiff and the State of Colorado as defendant.
- The complaint sought to treat the river ecosystem as a rights-bearing legal person capable of suing through human “next friends” or guardians.
- The pleading alleged the ecosystem’s continued existence and ecological functioning were threatened by climate change, water diversions, damming, and related development.
- The relief sought was declaratory judgment recognizing the ecosystem’s asserted rights (including to exist, flourish, regenerate, be restored, and naturally evolve) and a corresponding state duty not to violate those rights.
- After an amended complaint was filed and the State moved to dismiss, the plaintiff moved (unopposed) to dismiss its own case with prejudice, citing the novelty of the requested doctrinal change and counsel’s view that conditions were not appropriate for merits adjudication.
- The court granted the unopposed motion and dismissed the case with prejudice, ending the litigation without a decision on the substantive claims.

## Issues

1. Whether a river ecosystem may be recognized as a legal person with enforceable substantive rights under federal law.
2. Whether a river ecosystem may invoke federal jurisdiction and seek judicial relief through “next friend” or guardian representation.
3. Whether declaratory relief may be used to impose a duty on a state to refrain from conduct alleged to violate asserted ecosystem rights.
4. What legal effect follows from a plaintiff’s voluntary dismissal with prejudice in a federal declaratory judgment action.

## Decision

- The court granted the plaintiff’s unopposed motion for voluntary dismissal with prejudice.
- The case was terminated without adjudication of standing, personhood, or any rights-of-nature theory.
- No judicial findings were made regarding the requested declarations or the State’s motion to dismiss.

## Legal Principles

- A voluntary dismissal with prejudice ends the action and generally bars the plaintiff from reasserting the same claims against the same defendant in the same court.
- When a case is dismissed without a merits ruling, the court does not resolve the substantive legal questions raised in the pleadings.
- Declaratory judgment actions can be filed to obtain a declaration of legal rights and duties, but those requests require a live case or controversy and proper party standing; here, those questions were left unanswered due to dismissal.

## Conclusion

The case presented a federal declaratory-judgment attempt to secure judicial recognition of rights-of-nature personhood and standing for the Colorado River Ecosystem, but it ended in a voluntary dismissal with prejudice, leaving the substantive questions unresolved.


Colorado River Ecosystem v. State of Colorado, No. 1:17-cv-02316-NYW (D. Colo. 2017)