Courte Oreilles Lakes Association Inc. v. Zawistowski, Rosalind

CourtDistrict Court, W.D. Wisconsin
DecidedFebruary 7, 2025
Docket3:24-cv-00128
StatusUnknown

This text of Courte Oreilles Lakes Association Inc. v. Zawistowski, Rosalind (Courte Oreilles Lakes Association Inc. v. Zawistowski, Rosalind) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Courte Oreilles Lakes Association Inc. v. Zawistowski, Rosalind, (W.D. Wis. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

COURTE OREILLES LAKES ASSOCIATION INC, and LAC COURTE OREILLES BAND OF THE LAKE SUPERIOR CHIPPEWA,

Plaintiffs, OPINION and ORDER v. 24-cv-128-jdp ROSALIND C. ZAWISTOWSKI, as trustee of the Zawistowski Joint Revocable Trust,

Defendant.

This case brought under the Clean Water Act (CWA) is about the discharge of phosphorus into Lac Courte Oreilles, a lake in northern Wisconsin. Defendant Zawistowski Joint Revocable Trust owns two cranberry marshes next to the lake. The plaintiffs are a property-owners association devoted to protecting the lake and a tribe that has treaty rights over the lake. Plaintiffs contend that the trust is violating the CWA by discharging phosphorus into the lake without a permit. Both sides move for summary judgment. The trust does not dispute that it is discharging phosphorus into the lake without a permit. The question is whether the permit requirement applies to the trust’s conduct. Both the Wisconsin Department of Natural Resources (DNR) and the Environmental Protection Agency (EPA) have concluded that the permitting requirement does not apply to cranberry farms under an exclusion in the CWA for “return flows from irrigated agriculture,” and they have rejected plaintiffs’ calls to apply the permitting requirement to the trust. The agencies’ understanding of the exclusion is consistent with both the plain language of the statute and legislative history. Plaintiffs’ primary argument in support of a contrary view is that including cranberry farms in the exclusion for “irrigated agriculture” creates a “massive loophole” in the CWA, which is contrary to the CWA’s purpose to protect the nation’s navigable waters. Regardless of whether that is correct, the “loophole” is one that Congress inserted, so the court cannot

disregard it. Plaintiffs have identified no basis for limiting the scope of the exclusion in the way they suggest. The court will grant the trust’s motion for summary judgment and deny plaintiffs’ motion.

BACKGROUND The Courte Oreilles Lakes Association represents approximately 650 property owners on and surrounding Lac Courte Oreilles and Little Lac Courte Oreilles. The association’s mission statement sets forth two purposes: (1) to protect, preserve and enhance the quality of the Courte Oreilles Lakes, their shorelands and surrounding areas, while respecting the interests of property owners and the rights of the general public, and (2) to consider, study, survey and respond to issues deemed relevant by the membership of the organization. Dkt. 81, ¶ 2. Lac Courte Oreilles Band of the Lake Superior Chippewa is one of six bands of the Lake Superior Chippewa Indians. Approximately one third of Lac Courte Oreilles lies within the tribe’s reservation. The tribe has treaty rights over the rest of the lake, including fishing rights. Zawistowski Joint Revocable Trust owns two cranberry marshes on Musky Bay, which is part of Lac Courte Oreilles.' The east marsh has 20 acres of production, with a typical yield of 4,000 barrels of cranberries, and the west marsh has 60 acres of production, with a typical yield of 8,000 barrels. The bay and the marshes are shown in the aerial photograph below: a OS ————E — □ ee: b= Cen □□ ee . see eal =) -~wiwes oe) □□□ a Seer meres! oe

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The trust fertilizes its cranberry beds with a combination of phosphorus, nitrogen, and potassium.

' The trust says that a different entity, W.D.Z. Cranberries, runs the cranberry farm. But the trust does not challenge plaintiffs’ claim on the ground that it is the wrong defendant or that W.D.Z. should be joined, so the court does not consider that issue.

In the fall each year, the trust floods the cranberry marshes with water from the lake to harvest the cranberries. In the winter, the marshes are flooded with lake water to protect plants from dying. Lake water is also used for plant growth, for pest control, as a herbicide, and to protect plants from frost. Water that is used for these purposes is returned to the lake through

man-made channels that connect the marshes to the lake. From 2019 to 2024, plaintiffs took water samples at the outlets for the east and west marshes. These samples show phosphorus concentrations between 27 parts per billion (ppb) and 470 ppb. The DNR has established a criterion of 10 ppb for phosphorus in the lake. Wis. Admin. Code § NR 102.06(7)(b)4. The phosphorus concentrations at the marsh outlets are on average eight to ten times higher than the concentrations in other parts of the lake. The trust does not have a permit for discharging phosphorus into the lake. In 1989, the DNR determined that the trust’s cranberry farm in particular and cranberry farms in general

did not need a permit to comply with the CWA. In 2019 and 2023, the DNR again stated its view that the CWA does not allow the DNR to require permits for water pollution caused by cranberry marshes. In response to an inquiry from the tribe, an EPA official stated in 2013 that “EPA had concluded that discharges from cranberry bogs into waters of the United States are irrigation return flows not subject to [CWA] permitting requirements.” Dkt. 30-6. The court will discuss other facts as they become relevant to the analysis.

ANALYSIS A. Standing

All plaintiffs in federal court must show that they have standing to sue. The trust does not challenge plaintiffs’ standing, but, as plaintiffs recognize, the court has an independent obligation to confirm that it has subject matter jurisdiction, and that includes the plaintiffs’ standing. See Prairie Rivers Network v. Dynegy Midwest Generation, LLC, 2 F.4th 1002, 1012 (7th Cir. 2021). This is especially true when, as in this case, the plaintiffs are challenging government regulation of a third party rather than themselves, so the connection between the

plaintiffs and the challenged conduct is more attenuated. See Food and Drug Administration v. Alliance for Hippocratic Medicine, 602 U.S. 367, 382–85 (2024). Plaintiffs must show three things to establish standing: (1) a concrete injury; (2) causation; and (3) redressability. Id. at 380. 1. Association The court will consider the association’s standing first. The association says that it has standing in two ways. First, it says it is harmed directly because one of its primary purposes is to “protect, preserve, and enhance the quality” of the lakes, and it has spent more than

$100,000 to both reduce the weeds and restock the muskie population. Dkt. 81, ¶¶ 2, 107–08. Second, it says that it is harmed through its members, who are property owners around the lake. It cites declarations of members who say that they cannot go boating in some areas of the lake because of the weeds, and they are catching fewer and smaller muskie. The court concludes that the association has established standing under the first theory, so it is unnecessary to consider the second. The following facts are undisputed: phosphorus is in the fertilizer that the trust uses on its cranberry farm, Dkt. 81, ¶¶ 19, 22–24; some of the fertilizer is discharged into the lake,

id., ¶ 37; the lake has elevated concentrations of phosphorus, especially around the trust’s marshes, id., ¶¶ 50–60; increased concentration of phosphorus leads to the growth of more algae and other aquatic invasive species, id., ¶ 69; algae consumes oxygen, which reduces the amount of oxygen in the water, which, in turn, leads to the death of fish and fish larvae, id. ¶¶ 70–71, 73–75; the association has spent more than $100,000 to kill and remove aquatic invasive species and to restock the lake with muskie fish, id., ¶¶ 107–08. These undisputed facts are enough to show that the association has standing.

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Courte Oreilles Lakes Association Inc. v. Zawistowski, Rosalind, Counsel Stack Legal Research, https://law.counselstack.com/opinion/courte-oreilles-lakes-association-inc-v-zawistowski-rosalind-wiwd-2025.