In Idaho Conservation League, Inc. v. Russell, 946 F.2d 717 (9th Cir. 1991), an environmental group initiated an action against EPA under the Act, asserting that EPA failed to perform a mandatory duty to issue water quality regulations for the state of Idaho. The state of Idaho intervened in the matter. After the environmental group reached an agreement with the state of Idaho, whereby Idaho would adopt water quality standards, the environmental group moved to dismiss its lawsuit against EPA, but also sought attorneys' fees from EPA. A federal district court granted that application. EPA appealed the decision to the Ninth Circuit, which reversed the award of attorneys' fees. The Ninth Circuit applied the catalyst rule, observing that all an applicant for fees needs to demonstrate is that the fee-seeking party obtained the relief it sought in the lawsuit as a consequence of bringing the lawsuit and that the lawsuit had a genuine basis in law. The Ninth Circuit reasoned that, in considering fee requests, courts should look to the objective of the plaintiff in bringing the lawsuit and what the plaintiff actually obtained as a result of the lawsuit. This inquiry involves an examination of cause and effect. In the matter before it, the environmental group obtained what it was seeking in the lawsuit--state water quality standards. The court reflected upon EPA's failure to comply with the Act's mandate that EPA should promulgate water quality regulations if a state fails to do so. Id. at 720. The Ninth Circuit, however, agreed with EPA that in order to constitute a prevailing party, a party must prevail over a party against which it brought its lawsuit. Relying upon a United States Supreme Court decision, Ruckelshaus v. Sierra Club, 463 U.S. 680, 103 S. Ct. 3274, 77 L. Ed. 2d 938 (1983), the Ninth Circuit noted that the traditional view in fee-shifting applications warrants the award of fees against the losing party--the party responsible for providing relief on the merits. In other words, in any litigation, there might be more than one party from which a plaintiff seeks relief, but the plaintiff will only be prevailing as to those defendants which ultimately provide some of the relief, including the practical relief, requested. Id. at 720-21. The Ninth Circuit acknowledged that the environmental group's lawsuit acted as a catalyst that prompted an opposing party (the state of Idaho) to take action, but the lawsuit never prompted the party from which the group sought fees, EPA, to provide the relief the group sought. Id. at 721.