Editors' Summary: In December 1987 the Supreme Court held, in Gwaltney of Smithfield, Ltd. v. Chesapeake Bay Foundation, Inc., that citizens could not obtain civil penalties under §505 of the Federal Water Pollution Control Act (FWPCA) for violations that occurred wholly in the past. The ruling seemingly resolved a three-way split among the federal circuit courts of appeal on the scope of such citizen suits. But the Court's analysis actually leaves a number of questions unanswered, as the author of this Article observes. His examination of the FWPCA's citizen suit provision and the legislative history leads him to conclude that §505 is not drafted with the precision that the Court ascribes to it. Moreover, the Court's ruling that a citizen suit can be maintained if there are good-faith allegations of continuing or intermittent violations still leaves open many issues with which trial courts will have to wrestle. The author concludes that far from leading to fewer FWPCA §505 actions, the Court's ruling may well result in additional litigation.