## Facts

- The U.S. Navy used Vieques, Puerto Rico, for weapons training involving artillery, strafing, and air-to-ground bombing on land and at sea.
- Ordnance sometimes entered surrounding navigable waters, either from missed land targets or by use of water targets.
- Puerto Rico officials and agencies sued, alleging the Navy discharged pollutants into navigable waters without a Clean Water Act (FWPCA) permit under the NPDES program.
- The district court found the ordnance discharges were pollutants from a point source into navigable waters and therefore violated the FWPCA because no permit had been obtained.
- The district court also found the record did not show the discharges had harmed water quality.
- The district court ordered the Navy to apply for an NPDES permit but declined to halt training operations while the application was pending.
- The First Circuit required an injunction stopping discharges until a permit issued, reasoning that injunctive relief was mandatory once a violation was found.

## Issues

1. Whether the FWPCA requires federal courts to issue an immediate injunction halting unpermitted discharges upon finding a statutory violation.
2. Whether a district court retains traditional equitable discretion to order other relief (such as requiring a permit application) when enforcing the FWPCA.

## Decision

- The Supreme Court reversed the First Circuit.
- The Court held the FWPCA does not eliminate a district court’s equitable discretion and does not require automatic injunctions for every violation.
- The Act permits courts to order relief they consider necessary to secure prompt compliance, which may include but is not limited to immediate cessation of discharges.
- The Court concluded the district court acted within its discretion in ordering the Navy to seek a permit without immediately enjoining operations, given its factual findings and consideration of public consequences.

## Legal Principles

- Absent a clear congressional command, federal courts retain traditional equitable discretion when enforcing statutes and are not mechanically required to issue injunctions for every violation.
- Injunctive relief remains an extraordinary remedy; courts may consider irreparable injury, inadequacy of legal remedies, and the public consequences of an injunction.
- The Clean Water Act’s remedial structure (including permits, penalties, and criminal sanctions) indicates Congress did not require automatic shutdown injunctions as the sole response to unpermitted discharges.
- Appellate review of the grant or denial of injunctive relief is for abuse of discretion; a court of appeals errs by treating an injunction as mandatory and substituting its judgment for the trial court’s.

## Conclusion

The Court held that Clean Water Act violations do not automatically compel an injunction and that district courts may balance equitable factors and the public interest to craft remedies that secure prompt statutory compliance.


Weinberger v. Romero-Barcelo, 456 U.S. 305 (1982)