United States v. Andrews

CourtCourt of Appeals for the Second Circuit
DecidedMarch 19, 2025
Docket24-1479
StatusUnpublished

This text of United States v. Andrews (United States v. Andrews) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Andrews, (2d Cir. 2025).

Opinion

24-1479 United States v. Andrews

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 19th day of March, two thousand twenty-five.

Present: BARRINGTON D. PARKER, MICHAEL H. PARK, ALISON J. NATHAN, Circuit Judges. _____________________________________

UNITED STATES OF AMERICA,

Plaintiff-Counter- Defendant-Appellee,

v. 24-1479

JEFFREY ANDREWS,

Defendant-Counter- Claimant-Appellant. * _____________________________________

* The Clerk of the Court is respectfully directed to amend the caption as set forth above. FOR PLAINTIFF- APPELLEE: Arielle Mourrain Jeffries, for Todd Kim, Assistant Attorney General, United States Department of Justice, Washington, DC.

FOR DEFENDANT- APPELLANT: Jeffrey Andrews, pro se, Wallingford, CT.

Appeal from an order of the United States District Court for the District of Connecticut

(Hall, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the order of the district court is AFFIRMED.

In 2020, the United States, on behalf of the Environmental Protection Agency (“EPA”),

filed a civil complaint against Jeffrey Andrews, claiming that he violated the Clean Water Act

(“CWA”) by (1) discharging pollutants into the waters of the United States, in violation of CWA

Section 301(a); and (2) refusing to provide information and access required by the EPA, in

violation of CWA Section 308. 1

The district court granted the government’s motion for summary judgment on Andrews’s

liability and entered an order on remedies and injunctive relief. 2 See United States v. Andrews,

677 F. Supp. 3d 74 (D. Conn. 2023). The district court later entered a “default and final judgment,”

1 The complaint also named Andrews’s wife and children. The district court granted default judgment against them. See United States v. Andrews, No. 3:20-CV-1300 (JCH), 2024 WL 2801708 (D. Conn. May 2, 2024). On appeal, Andrews at times refers to his wife and children, but we construe his brief as representing only himself and do not address the arguments he purports to raise on behalf of his family. See Tindall v. Poultney High Sch. Dist., 414 F.3d 281, 284 (2d Cir. 2005) (“[A] parent not admitted to the bar cannot bring an action pro se in federal court on behalf of his or her child.”). 2 The district court later entered a partial final judgment as to liability and injunctive relief against Andrews, pursuant to Fed. R. Civ. P. 54(b). Andrews elected not to appeal until after the district court entered its judgment as to the other defendants. Neither his notice of appeal nor amended notice of appeal identifies the Rule 54(b) dismissal. 2 reiterating the terms of the injunction and specifying that Andrews was jointly and severally liable

with the other defendants for restoration costs. See United States v. Andrews, No. 3:20-CV-1300

(JCH), 2024 WL 2800232 (D. Conn. May 3, 2024). Proceeding pro se, Andrew now appeals the

district court’s May 3, 2024 order. We assume the parties’ familiarity with the underlying facts,

the procedural history, and the issues on appeal.

I. Appellate Jurisdiction

The district court has not issued a “final decision” within the meaning of 28 U.S.C. § 1291

because it has not decided whether to impose civil penalties and if so how much. See RSS

WFCM2018-C44-NY LOD, LLC v. Lexington Operating DE LLC, 59 F.4th 586, 590 (2d Cir. 2023)

(“[A] finding of liability is ordinarily not treated as a final decision for purposes of section 1291

when questions of remedy remain unresolved.”). Still, we have jurisdiction over “[i]nterlocutory

orders . . . granting, continuing, modifying, refusing, or dissolving injunctions.” 28 U.S.C.

§ 1292(a)(1). And because the order Andrews appeals entered injunctive relief against him, “we

may also address the summary judgment order that served as the district court’s principal legal

basis for granting the injunction.” Shakhnes v. Berlin, 689 F.3d 244, 250 n.3 (2d Cir. 2012)

(quotation marks omitted).

II. Liability

“We review de novo the District Court’s grant of summary judgment.” 1077 Madison St.,

LLC v. Daniels, 954 F.3d 460, 463 (2d Cir. 2020). “Summary judgment is proper only when,

construing the evidence in the light most favorable to the non-movant, there is no genuine dispute

as to any material fact and the movant is entitled to judgment as a matter of law.” Doninger v.

Niehoff, 642 F.3d 334, 344 (2d Cir. 2011) (quotation marks omitted).

3 Section 301 of the CWA prohibits the “discharge of any pollutant” into “navigable waters”

without a permit issued by the EPA. 33 U.S.C. §§ 1311(a), 1342. Section 308 requires owners of

“any point source” to provide information to the EPA as it “may reasonably require” to determine

whether a violation has occurred. Id. § 1318(a). Here, Andrews admits that he never acquired a

permit. And he does not deny his failure to comply with the EPA’s requests for information and

access to his property. Instead, Andrews argues that the case should have been dismissed because

there is no surface water on his property. See Appellant’s Br. at 6-7. We disagree.

The CWA applies to wetlands that have “a continuous surface connection” with “relatively

permanent bod[ies] of water connected to traditional interstate navigable waters.” Sackett v. EPA,

598 U.S. 651, 678 (2023) (cleaned up). So the CWA does not require surface water but only soil

that is regularly “saturated by surface or ground water.” 33 C.F.R. § 328.3(c)(1). And Andrews

fails to rebut the expert report concluding that his property had wetlands connected to traditional

navigable waters.

Andrews next contends that the district court did not properly apply the Submerged Lands

Act and Supreme Court precedent. See Appellant’s Br. at 7-10, 12-13. But the Submerged Lands

Act is inapposite to violations of the CWA. See generally 43 U.S.C. §§ 1301 et seq.; Alaska v.

United States,

Related

Kaiser Aetna v. United States
444 U.S. 164 (Supreme Court, 1979)
United States v. Riverside Bayview Homes, Inc.
474 U.S. 121 (Supreme Court, 1985)
Lucas v. South Carolina Coastal Council
505 U.S. 1003 (Supreme Court, 1992)
Doninger v. Niehoff
642 F.3d 334 (Second Circuit, 2011)
Alaska v. United States
545 U.S. 75 (Supreme Court, 2005)
Shakhnes Ex Rel. Shakhnes v. Berlin
689 F.3d 244 (Second Circuit, 2012)
Koontz v. St. Johns River Water Management Dist.
133 S. Ct. 2586 (Supreme Court, 2013)
1077 Madison Street, LLC v. March
954 F.3d 460 (Second Circuit, 2020)
Green v. Dep't of Educ.
16 F.4th 1070 (Second Circuit, 2021)
Picard v. Magliano
42 F.4th 89 (Second Circuit, 2022)
Sackett v. EPA
598 U.S. 651 (Supreme Court, 2023)

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Bluebook (online)
United States v. Andrews, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-andrews-ca2-2025.