National Association of Manufacturers v. Department of Defense

In 2015, the U.S. Army Corps of Engineers and the Environmental Protection Agency jointly promulgated the "Waters of the United States" (WOTUS) rule, which defined the scope of waters protected under the Clean Water Act. Industry groups and states challenged the rule in both district and circuit courts. The central procedural question was which court had original jurisdiction to hear the challenges. The Clean Water Act channels direct appellate review for certain agency actions, while others must begin in federal district court. The Sixth Circuit held that it had jurisdiction. The Supreme Court granted certiorari and, in a unanimous decision delivered by Justice Sotomayor on January 22, 2018, reversed, holding that the WOTUS rule did not fall within the narrow categories subject to direct circuit court review, because it was a definitional rule rather than an effluent limitation or permit issuance. Consequently, challenges had to be filed in district court.

The U.S. Supreme Court unanimously ruled that federal district courts, not the courts of appeals, have original jurisdiction to hear challenges to the WOTUS rule. The judgment of the Sixth Circuit was reversed, and the case was remanded for further proceedings.

Whether challenges to the 2015 "Waters of the United States" rule must be brought in federal district courts or directly in the federal courts of appeals under the Clean Water Act's judicial review provision.

The decision clarified the jurisdictional framework for environmental regulatory litigation and effectively ensured that challenges to the WOTUS rule would proceed in multiple district courts rather than a single appellate court. This procedural outcome further fueled the national debate over the scope of federal water regulation, delayed a definitive substantive ruling on the 2015 rule, and influenced the Trump administration's subsequent efforts to repeal and replace the rule with a narrower definition, which itself triggered new rounds of litigation.