Int'l Paper Co. v. Ouellette - 479 U.S. 481, 107 S. Ct. 805 (1987)

Rule:

A state law also is preempted if it interferes with the methods by which a federal statute is designed to reach a legislative goal.

Facts:

A group of Vermont lakeshore property owners sought compensatory damages, punitive damages, and injunctive relief in a suit originally filed in Vermont Superior Court, and later removed to the United States District Court for the District of Vermont. The owners claimed that petitioner International Paper Company had created a "continuing nuisance" under Vermont common law, where (1) a New York paper mill of the company discharged effluents into Lake Champlain near the state boundary, and (2) the discharge allegedly made the water foul, unhealthy, smelly, and unfit for recreational use, thereby diminishing the value of the owners' Vermont property. Arguing that such a state-law claim was pre-empted by the Clean Water Act (also known as the Federal Water Pollution Control Act) (33 USCS 1251 et seq.), the company moved for summary judgment and judgment on the pleadings. The District Court, however, denied the motion and expressed the view that the Act authorized private actions to redress injuries caused by pollution of interstate waters, under the common law of the state in which the injury allegedly occurred, in view of the express language of two state-law savings provisions in 505(e) and 510 of the Act (33 USCS 1365(e), 1370), the legislative history of the Act, and the stated objectives of the Act. On appeal, the United States Court of Appeals for the Second Circuit affirmed, stating that it did so essentially for the reasons set forth in the District Court's opinion. Petitioner challenged the decision.

Issue:

1. Did the Clean Water Act preclude the court from applying Vemont law against the petitioner? 
2. Under the circumstances, did the lower courts err in refusing to dismiss the plaintiffs’ common-law nuisance suit?

Answer:

1) Yes. 2) No.

Conclusion:

Reversing the lower court's finding that Vermont law governed the suit, the Court found that the CWA precluded the Court from applying Vermont law against the paper mill operator. Because bringing suit under Vermont law as the affected state would have disrupted the balance of interests established under the CWA, the Court held that Vermont law was inapplicable to the paper mill operator because the point source of the pollution was New York. While reversing the application of Vermont law, the Court affirmed the denial of the paper mill operator's motion to dismiss, noting that the CWA did not prohibit the property owners from bringing a state nuisance claim under the law of the polluting source state.