Comment, When (Moving) Dirt Hurts: How the Ninth Circuit in Borden Ranch Partnership v. United States Army Corps of Engineers Could Have Better Justified its Decision to Protect Wetlands (Borden Ranch P’ship v. U.S. Army Corps of Eng’rs, 537 U.S. 99, 2002 [Borden III]), 27 UNIV. HAWAII L. REV. 417-439 (2005).