Summary of TVA v. Hill
Citation: 437 U.S. 153
Relevant Facts: In 1967, The Tennessee Valley Authority started building the Tellico Dam on the Little Tennessee River. The operation was occurring where there were endangered fish species, one of which, the snail darter, had been found upstream. Several years later, the Endangered Species Act was passed by Congress in 1973. Had the dam project been completed, the reservoir would harm the snail darter’s habitat. Consequently, the Department of the Interior filed suit to get an injunction to stop the completion of the dam. The trial court found in favor of the TVA, and the DOI appealed the matter to the Court of Appeals. Consequently, the TVA appealed the matter to the Supreme Court.
Issues: The legal questions presented were whether the ESA required courts to enjoin the operation of federal dam projects when they are nearly complete when it has been found that such completion may harm the natural habitat of an endangered species, and whether continued congressional funding of the dam project after the passing of the ESA indicated that the ESA had been effectively repealed.
Holding: The Supreme Court upheld the injunction.
Reasoning: The Court found that the completion of the dam ran contrary to the language as explicitly provided in the ESA of 1973. It also found that although risks and rewards must be weighed, and arguably when weighed between stopping a multimillion dollar government project for the benefit of saving endangered fish, the ESA had provided for just that because the loss of those fish was deemed to be “incalculable." In other words, the Court nor Congress had no way of knowing how detrimental the extinction or at least further endangerment of the snail darter could be to ecosystems, and by extension economies. The Court provided this decision, also asserting that on its face it may seem absurd, but that the language of the law of the ESA of 1973 was nevertheless clear.