United States v. Metro. Water Reclamation Dist. of Greater Chi.

摘要

Environmental groups may not bring Clean Water Act citizen suit claims against Illinois municipal water district for alleged stormwater discharge violations after district entered into consent decree with federal government and Illinois to address those violations in civil enforcement action, because, even though groups opposed decree and doctrine of res judicata does not bar their claims: (1) under act citizen suit claims may not be brought if federal government or state is diligently prosecuting same alleged violations, (2) federal district court did not abuse its discretion in finding decree is reasonable, and (3) decree constitutes diligent prosecution.