United States v. Plaza Health Laboratories, Inc. 3 F.3d 643 (2d. Cir. 1993) Villegas was the owner of Plaza Health Laboratories.  He filled up his car with vials of human blood that the lab had sampled, took them to the Hudson River, and tossed them in. The vials were later found by schoolchildren on a field trip. EPA charged Villegas with violating the Clean Water Act by knowingly discharging pollutants into the Hudson River. Villegas argued that the Clean Water Act only applies to point source discharges, and he was not a 'point source', and therefore was not covered by the Clean Water Act. The Clean Water Act lists examples of point sources as "pipes, ditches, channels, tunnels, etc" which invoke physical structures, not people.  However the list is nonexclusive. The Trial Court convicted Villegas of violating the Clean Water Act.  He appealed. The Appellate Court overturned the convictions. The Appellate Court found that if Congress had intended the Clean Water Act to include dumping by people, it could have said "any person who places pollutants in navigable waters without a permit is guilty of a crime," but it doesn't say that. A reading of the law shows that it is primarily focused on industrial and municipal sources of pollution. The Appellate Court found that since it is not clear whether Congress intended the Clean Water Act to apply to human beings, and EPA had not previously issued a ruling on whether it did or not, Villegas had no warning that what he was doing might be illegal. The Appellate Court suggested that the government should have prosecuted Villegas under the Rivers and Harbors Act instead. That act makes it a crime to throw trash into surface waters, but it is just a misdemeanor, not a felony like the Clean Water Act. In a dissent it was argued that the term "point source" has been broadly construed to include a wide range of polluting techniques, so there should be no problem in construing that it also included people. The purpose of the law was to prevent pollutants from entering waterways.  How could Congress have intended that it shouldn't include Villegas' actions? The Clean Water Act clearly delineates "point sources" from "non-point sources".  Since Villegas' actions sound more like a point source than a non-point source, they should be covered. "Villegas' activity functioned as a discrete conveyance." If Villegas was swimming in the water and decided to pee, should that be covered under the Clean Water Act?