ELR Citation: ELR 20815
No(s). 89-0746-H (D. Mass. Mar 28, 1990)

The court holds that penalties for Federal Water Pollution Control Act (FWPCA) violations in a citizen suit are available for pre-complaint violations. Plaintiffs must prove that the polluter committed post-complaint violations or that, at the time of trial, there is a reasonable likelihood that spo...