Editors' Summary: When the federal government filed a Clean Water Act enforcement action in 1981 against a real estate developer for unauthorized filling activities on Chincoteague Island, Virginia, the government could not have realized that it had set in motion litigation that would change how federal environmental laws are enforced. Five years later, however, the developer's claim that he was entitled to a jury trial eventually reached the Supreme Court. In Tull v. United States, the Court ruled that the Seventh Amendment guarantees a jury trial in Clean Water Act enforcement actions for civil penalties. This Article examines the case and its implications for federal enforcement of environmental laws. The author explores the expanded role that administrative penalties will likely play after Tull and the potential of alternative dispute resolution techniques to resolve environmental controversies.