Gwaltney of Smithfield, Ltd. v. Chesapeake Bay Foundation, Inc.

Environmental groups (plaintiffs) sued Gwaltney (defendant) under the Clean Water Act's citizen-suit provision, alleging its meat-packing plant had violated, and continued to violate, its discharge permit by exceeding pollutant limits, though Gwaltney's last recorded violation occurred several weeks before the complaint was filed; the district court granted partial summary judgment for the plaintiffs and found ongoing violations, but Gwaltney moved to dismiss, arguing the statute required an actual violation at the time of filing and the court therefore lacked jurisdiction since no violation existed exactly then. The district court and court of appeals both rejected that argument, and Gwaltney appealed.