TVA v. Hill
Citation
437 U.S. 153 (U.S. Supreme Court, 1978)
Facts
The Tennessee Valley Authority was nearly finished constructing the Tellico Dam when Congress passed the Endangered Species Act (ESA). Biologists discovered that the snail darter, a small fish listed as an endangered species, lived in the river that would be destroyed by the dam’s reservoir. Plaintiffs sued to halt dam construction as a violation of the ESA’s prohibition on federal actions that jeopardize listed species.
Issue
Whether the Endangered Species Act required halting the nearly complete Tellico Dam to protect the snail darter, despite the enormous financial costs already incurred.
Holding
The Supreme Court held that the ESA’s plain language required enjoining completion of the dam, regardless of the costs or the fact that the dam was nearly complete when the Act was passed.
Rule
When Congress enacts unambiguous statutory language with no exceptions, courts must enforce it literally regardless of the consequences; legislative history suggesting a contrary purpose cannot override clear text.