State of Florida, Plaintiff v. State of Georgia.

Summary

Florida challenged Georgia's upstream water consumption under the equitable apportionment doctrine, claiming harm to its Apalachicola oyster industry. The Special Master recommended dismissal, concluding Florida had not proven by clear and convincing evidence that a cap on Georgia's use would redress its injury without binding the U.S. Army Corps of Engineers. The Supreme Court remanded the case, holding the Special Master applied too strict a standard regarding redressability and that Florida had made a sufficient initial showing that an equitable decree could be fashioned.