Train v. Colorado Public Interest Research Group, Inc.
United States Supreme Court
426 U.S. 1 (1976)
Relevant factsFree
The EPA (defendant), administering the Federal Water Pollution Control Act's permit program, excluded from that program any radioactive materials already regulated under the Atomic Energy Commission's separate scheme; environmental groups (plaintiffs) sued to require the EPA to include all radioactive discharges, and the court of appeals held that the FWPCA's text defining "pollutant" to include radioactive materials, without exception, required the EPA to regulate them.
IssueFree
Whether, when interpreting a statute's text, a court may look to the statute's legislative history rather than restricting itself to the text alone.