Florida Wildlife Federation Inc. v. United States Army Corps of Engineers
859 F.3d 1306
| 11th Cir. | 2017Background
- Conservationists sued the Corps under the Clean Water Act alleging Florida Water Regulations and Florida Water Resources Act violations from the Corps’s management of locks S-77, S-78, and S-79 on the Okeechobee Waterway.
- The Water District, Florida’s State agency and local project sponsor, argues it is indispensable under Rule 19(b) and that its absence would impair state interests.
- The district court dismissed the suit on sovereign-immunity grounds and, alternatively, found Rule 19(b) did not permit proceeding without the Water District or DEP.
- Conservationists voluntarily dismissed the Water District and DEP; Water District sought limited intervention and to preserve Rule 19(b) arguments.
- The appellate court held the Water District is indispensable under Rule 19(b) and affirmed dismissal on that basis, without addressing sovereign immunity or sequencing.
- The decision relies on the interaction of federal navigation authority and state regulatory interests, invoking Rule 19(b) factors and related Supreme Court sovereign-immunity doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the Water District indispensable under Rule 19(b)? | Conservationists argue the Water District’s absence would not impair the case's disposition. | Water District contends it is indispensable due to its ownership/operation role and sovereign interests. | Yes; the Water District is indispensable under Rule 19(b). |
| Should the case be dismissed under Rule 19(b) rather than Rule 12(b)(1) sovereign immunity? | Court should decide sovereign immunity first; otherwise needlessly foreclose state interests. | Dismissing on sovereign immunity is appropriate and separate from Rule 19(b) concerns. | Rule 19(b) governs; case affirmed on Rule 19(b) grounds. |
| Does invoking sovereign immunity require dismissal regardless of Rule 19(b)? | Conservationists rely on federal question and Florida law; sovereign immunity may not bar all relief. | Sovereign immunity bars suits that affect navigation authority under § 1371(a). | Court does not reach this issue because Rule 19(b) dictates dismissal. |
Key Cases Cited
- Republic of Philippines v. Pimentel, 553 U.S. 851 (2008) (indispensable-sovereign immunity and absence considerations under Rule 19(b))
- Sinochem Int’l Co. Ltd. v. Malaysia Int’l Shipping Corp., 549 U.S. 422 (2007) (nonmerits threshold dismissal when warranted by convenience and efficiency)
- Levin v. Commerce Energy, Inc., 560 U.S. 413 (2010) (jurisdictional sequencing and nonmerits grounds)
- Steel Co. v. Citizens for Better Environment, 523 U.S. 83 (1998) (hypothetical jurisdiction rejected; threshold grounds sequencing)
- Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574 (1999) (threshold grounds sequencing for dismissal when merits are complex)
- Provident Tradesmens Bank & Trust Co. v. Patterson, 390 U.S. 102 (1968) (indispensable-party doctrine governing joinder and comity considerations)
- Am. Dental Ass’n v. Cigna Corp., 605 F.3d 1283 (11th Cir. 2010) (articulates sequencing principles in dismissal decisions)