U.S. Control Over Extraterritorial Water Pollution: The Interplay Between International and Domestic Law

摘要

Of course, Ionia Management was only a U.S. District Court decision and thus does not have the same force as a U.S. Supreme Court decision. However, the recent judicial trend of using domestic law in conjunction with and as a means of respecting notions of international law suggests a promising future for international environmental law. It remains to be seen whether the U.S. Supreme Court will approve of the principles embodied in Ionia Management. As more and more lower courts do so, however, it will be increasingly difficult for the Supreme Court to ignore this tendency.