The Eighth Circuit held that a U.S. Army Corps of Engineers jurisdictional determination (JD) is a final agency action under the APA, thereby creating a split between the circuits.

The Fifth Circuit reversed and remanded a lower court decision ordering EPA to determine whether new water quality standards were necessary to control nitrogen and phosphorus pollution in the mainstem of the Mississippi River and the Northern Gulf of Mexico.

A district court granted summary judgment in favor of a coal company, thereby dismissing environmental groups' CWA claim that the company violated its NPDES permit.