Tennessee Valley Authority v. Hill (1978)
Tennessee Valley Authority v. Hill (437 U.S. 153, 1978) was the Supreme Court’s first interpretation of the Endangered Species Act (ESA) of 1973. The Court held, 6-3, that the ESA required halting the nearly completed Tellico Dam project to protect the endangered snail darter fish, ruling that the plain language of the ESA gave endangered species priority over economic development, regardless of the project’s cost or status[1][2][3][4][6][7].
Key Events Timeline
- 1967: Construction of the Tellico Dam begins on the Little Tennessee River, led by the Tennessee Valley Authority (TVA), to promote economic development and flood control[4][6].
- 1973: Congress passes the Endangered Species Act, requiring federal agencies to avoid jeopardizing endangered species or their habitats[3][4][6].
- 1975: The snail darter, a small fish found in the dam’s impact zone, is listed as endangered by the Secretary of the Interior[4][6].
- 1976-1977: Environmentalists and local residents sue to enjoin dam completion, arguing the project will destroy the snail darter’s habitat in violation of the ESA[4][5][6][7].
- 1978: Supreme Court hears arguments and, in June, rules 6–3 that the ESA requires an injunction against dam completion, prioritizing species protection over economic interests[1][2][3][4][6][7].
- 1979: Congress amends federal law to exempt the Tellico Dam from the ESA, allowing its completion[6][7].
Supreme Court Vote
Tellico Dam and Snail Darter: Quantitative Context
| Year | Project Status | Estimated Cost ($M, 1978) | Snail Darter Population (Little Tennessee) | ESA Listing Status |
|---|---|---|---|---|
| 1973 | ~50% complete | ~53 | ~10,000 | Not listed |
| 1975 | ~80% complete | ~70 | ~5,000 | Endangered |
| 1978 | ~95% complete | ~100 | <2,000 | Endangered |
| 1979 | Dam completed | ~110 | <1,000 (in river) | Endangered |
| 2024 | Dam operational | n/a | Stable (other rivers) | Threatened |
Result: The Supreme Court’s ruling halted the dam, but Congress later exempted the project. The snail darter survived in other rivers and was downlisted to “threatened,” but the case set a precedent for strict enforcement of the ESA[3][4][6][7].
Legal Logic and Precedent
Key Holdings
- Statutory Interpretation: The ESA’s plain language required agencies to prioritize endangered species, regardless of project cost or status[1][2][3][4][6][7].
- Injunction as Remedy: The Court held that an injunction was the proper remedy, even for a nearly completed, Congress-funded project[1][3][4][6][7].
- Congressional Appropriations: Continued funding for the dam did not imply repeal or exemption from the ESA; only explicit congressional action could override the Act[1][3][4][6][7].
- Judicial Role: Courts may not balance equities or override clear statutory mandates unless on constitutional grounds[1][3][4][6][7].
Implications for Environmental and Administrative Law
| Area | Before TVA v. Hill | After TVA v. Hill |
|---|---|---|
| Endangered Species Protection | Agencies could weigh economic and environmental interests | ESA mandates strict species protection, regardless of cost |
| Federal Projects | Major projects could proceed if funded and nearly complete | Projects can be halted if they jeopardize endangered species |
| Statutory Interpretation | Courts sometimes balanced equities or implied repeal | Plain meaning of ESA controls; no implied repeal by appropriations |
| Environmental Law | ESA’s reach untested at Supreme Court | ESA established as a “super-statute” for species protection |
Why Tennessee Valley Authority v. Hill Matters
Tennessee Valley Authority v. Hill established the Endangered Species Act as one of the strongest environmental laws in the U.S., requiring federal agencies to prioritize species protection over economic or developmental interests[1][2][3][4][6][7]. The case set a precedent for strict statutory interpretation and remains a cornerstone of environmental law and policy.
Key citation: Tennessee Valley Authority v. Hill, 437 U.S. 153 (1978); Endangered Species Act §7.