The Solid Waste Agency of Northern Cook County (SWANCC) v. United States Army Corps of Engineers case in 2000 revolved around the issue of federal jurisdiction over isolated wetlands. SWANCC, a consortium of suburban Chicago cities and villages, purchased an abandoned sand and gravel pit for the purpose of developing a solid waste disposal site. The U.S Army Corps denied them permission citing Section 404(a) under Clean Water Act which gave them authority over "waters" including intrastate lakes, rivers, streams etc., even if they were man-made or natural habitats for migratory birds only occasionally or seasonally. However, Supreme Court ruled in favor of SWANCC stating that Congress did not intend to give such broad authority to regulate land use to the Corps under Clean Water Act and hence it exceeded its power by trying to deny permit based on Migratory Bird Rule alone.

In the dissenting opinion for Solid Waste Agency of Northern Cook County v. United States Army Corps of Engineers, Justice Stevens argued that the majority's decision to limit federal jurisdiction over isolated wetlands was misguided and inconsistent with both precedent and legislative intent. He contended that Congress intended a broad interpretation of "waters" under the Clean Water Act, including intrastate waters such as those in question in this case. Furthermore, he emphasized that these isolated wetlands serve important ecological functions and their protection is crucial for maintaining biodiversity. The majority's narrow reading could potentially undermine efforts to protect these critical ecosystems from pollution or destruction due to human activities like waste disposal.