In Georgia v. Tennessee Copper Company, the Supreme Court decided that a polluting copper smelting operation could:

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In Georgia v. Tennessee Copper Company, the Supreme Court recognized the concept of transboundary pollution and allowed the state of Georgia to seek an injunction against the Tennessee Copper Company to reduce its harmful emissions that were affecting the air quality in Georgia. This case was significant for establishing that states could seek relief against air pollution damages from sources in other states, but it did not involve the federal government shutting down operations, imposing fines, or criminal charges under the Clean Air Act, which was not yet enacted at the time of this decision.

In Georgia V