Tennessee Riverkeeper, Inc. v. Waste Connections of Tennessee

CourtDistrict Court, M.D. Tennessee
DecidedMarch 6, 2025
Docket3:24-cv-00883
StatusUnknown

This text of Tennessee Riverkeeper, Inc. v. Waste Connections of Tennessee (Tennessee Riverkeeper, Inc. v. Waste Connections of Tennessee) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tennessee Riverkeeper, Inc. v. Waste Connections of Tennessee, (M.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

TENNESSEE RIVERKEEPER, ) ) Plaintiff, ) ) v. ) Case No. 3:24-cv-00883 ) Judge Aleta A. Trauger WASTE CONNECTIONS OF ) TENNESSEE, INC.1 ) ) Defendant. )

MEMORANDUM This case is an environmental citizen suit brought under the Clean Water Act and the Resource Conservation and Recovery Act. For the reasons set forth herein, the defendant’s pending Motion to Dismiss (Doc. No. 15) will be granted under Rule 12(b)(1), for lack of subject matter jurisdiction. I. FACTS AND PROCEDURAL HISTORY The plaintiff, Tennessee Riverkeeper, Inc. (“Riverkeeper”), is a non-profit corporation “dedicated to the preservation, protection, and defense of the Tennessee and Cumberland Rivers and their tributaries.” (Doc. No. 2 at 3; Doc. No. 1 ¶ 21.) The defendant, Waste Connections of Tennessee, Inc. (“Waste Connections”), is a privately held corporation. (Doc. No. 17 at 1.) Waste Connections conducts landfilling operations at its Hermitage property abutting the Stones River. (Doc. No. 1 ¶¶ 7, 58–59; Doc. No. 1-1 at 3.)

1 The Complaint’s caption omits the defendant’s corporate status. (Compare Doc. No. 1 at 1, with Doc. No. 17 at 1.) According to the Complaint, “Tennessee Riverkeeper’s scientist observed a discharge of discolored water into Stones River on June 6, 2023, June 27, 2023, and September 22, 2023.” (Doc. No. 1 ¶ 57.) The alleged discharge came from a “seep or spring on the banks of the river” on the defendant’s property.”2 (Id. ¶¶ 58–59.) Riverkeeper’s scientist collected a water sample on September 22, 2023.3 (Id. ¶ 60.) Laboratory tests revealed the presence of per- and polyfluoroalkyl

2 In its Response—for the first time, as the defendant notes (Doc. No. 25 at 4–5)— Riverkeeper “alleges that the materials buried on-site contain PFAS and other industrial chemicals. These buried materials are a conveyance of these chemicals[.] . . . The buried materials are therefore a point source. They then released these chemicals to groundwater which carries them to Stones River.” (Doc. No. 23 at 10.) 3 Some details of the plaintiff’s sampling are underspecified. The Complaint alleges the following: “Tennessee Riverkeeper’s scientist observed a discharge of discolored water into Stones River” on three dates, including September 22, 2023. (Doc. No. 1 ¶ 57.) “The location was on the Stones River at or about 36.18270º N, 86.63311º W. This location is a seep or spring on the banks of the river flowing into the river.” (Id. ¶ 58.) “Nashville Planning Department parcel records reveal that this location is owned by Waste Connections of Tennessee.” (Id. ¶ 59.) “Riverkeeper’s scientist collected a water sample on the September 22, 2023 visit.” (Id. ¶ 60.) Thus, the “location” the plaintiff describes is the location of the discharges the plaintiff alleges. And that location is “on the banks of the river flowing into the river” at or about the specified GPS coordinates—which, the defendant states, and, the court, taking judicial notice of Google Maps results, agrees, “[w]hen mapped . . . appears to be in the middle of the river.” (Doc. No. 16 at 8 n.8.) But the sampling’s location is unclear. First, the Complaint is ambiguous about—and the Response does not clarify—whether Riverkeeper’s scientist drew water from Stones River, as indicated by the GPS coordinates, or from the discharge the plaintiff alleges emanated from the defendant’s property. Second, as the defendant points out in its letter responding to the Notice, the sample’s chain of custody form, which Riverkeeper appended to its Notice, lists two different samples taken on September 22, 2023: one from “Stoners Spring” at 11:40 A.M., and one from “Stones River Spring” at 1:00 P.M. (See Doc. No. 16-5 at 5 (describing Doc. No. 1-1 at 9).) The court is able to resolve this ambiguity only because Riverkeeper filed the identical chain of custody form in a similar case concerning the other water sample the form lists. See Exhibit A at 13, Chain of Custody, Tenn. Riverkeeper, Inc. v. Tweden, No. 3:24-cv-886 (M.D. Tenn. July 22, 2024), (ECF No. 1-1) (listing the sample as from “Stoners Spring”). According to both parties, Stoners Creek substances (“PFAS”) in the water sample. (Id.; Doc. No. 1-1 at 7–9.) “PFAS” refers to a class of man-made chemicals that, the plaintiff states, may harm humans and animals. (Doc. No. 1 ¶¶ 62– 63.) On March 25, 2024, Riverkeeper sent Waste Connections a Notice of Intent to Sue Letter (“Notice”) (Doc. No. 1 ¶ 12), to which Waste Connections responded. (Doc. No. 16 at 19.)4

According to Riverkeeper, after it gave notice, “the violations complained of have not ceased, and are ongoing and neither the EPA nor the State of Tennessee has commenced and diligently prosecuted . . . [an] enforcement action.” (Doc. No. 1 ¶ 16; see also id. ¶ 67 (“The violations set forth in the paragraphs above and in the March notice are continuing and ongoing, or are likely to recur, as of the date this Complaint is being filed.”).) On July 22, 2024, the plaintiff filed the operative Complaint (Doc. No. 1.) The defendant has filed a Motion to Dismiss (Doc. No. 15), accompanying Memorandum (Doc. No. 16), and exhibits (Doc. Nos. 16-1 through 16-5), to which the plaintiff has filed a Response (Doc. No. 23) and an accompanying exhibit (Doc. No. 23-1.) The defendant has filed a Reply (Doc. No. 25) and accompanying exhibits (Doc. Nos. 25-1 through

25-5). Riverkeeper alleges three counts: violations of the Clean Water Act (Doc. No. 1 ¶¶ 68–78 (“Count One”)), violations of the Resource Conservation and Recovery Act (id. ¶¶ 79–88 (“Count Two”)), and a claim for “injunctive relief” (id. ¶¶ 89–95 (“Count Three”)). Waste Connections moves for dismissal under Rules 12(b)(1) and 12(b)(6). Waste Connections argues that this court lacks subject matter jurisdiction because the plaintiff provided inadequate notice of intent to sue

is a tributary of Stones River. (See Doc. No. 16-5 at 5); accord Amended Complaint ¶ 27, Tenn. Riverkeeper, Inc. v. Tweden, No. 3:24-cv-886 (M.D. Tenn. Nov. 12, 2024), (ECF No. 17). 4 Riverkeeper’s Notice and Waste Connection’s response letter are in the record at Doc. Nos. 1-1 and 16-5, respectively. While Waste Connections contests the Notice’s legal sufficiency, (see Doc. No. 16 at 7–9), it does not contest service. (Doc. No. 16 at 7–9), the plaintiff’s environmental claims are “wholly past” (id. at 9–11), and because the plaintiff lacks standing (id. at 11–15). In the alternative, Waste Connections argues that Riverkeeper failed to state a claim for any of its counts: the Clean Water Act claim does not identify a point source or discharge of pollutants from the defendant’s property (id. at 15–18), the Resource Conservation and Recovery Act claim ignores the defendant’s permit and relies on

inapplicable regulations (id. at 18–20), and a claim for injunctive relief is not a cause of action (id. at 20–21). Because the court finds the jurisdictional argument to be dispositive, the court will dismiss the Complaint under Rule 12(b)(1), without reaching the defendant’s arguments for dismissal under Rule 12(b)(6). II. LEGAL STANDARD – RULE 12(b)(1) Federal Rule of Civil Procedure 12(b)(1) governs dismissal for lack of subject matter jurisdiction. “Rule 12(b)(1) motions to dismiss . . . generally come in two varieties: a facial attack or a factual attack.” Gentek Bldg. Prods., Inc. v. Sherwin–Williams Co., 491 F.3d 320, 330 (6th Cir. 2007). When a Rule 12(b)(1) motion challenges subject matter jurisdiction based on the face

of the complaint, as this one does, the plaintiff’s burden is “not onerous.” Musson Theatrical Inc. v. Fed.

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Tennessee Riverkeeper, Inc. v. Waste Connections of Tennessee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tennessee-riverkeeper-inc-v-waste-connections-of-tennessee-tnmd-2025.