Editors' Summary: In Avoyelles Sportsmen's League, Inc. v. Marsh, the Fifth Circuit ruled that bottomland hardwood wetlands cannot be converted into farmland without an FWPCA §404 permit. The court endorsed EPA's broad interpretatin of wetlands and established a deferential standard for review of EPA wetland determinations. The author analyzes these rulingsand the changing role of the courts in the implementation of §404.