The Supreme Court’s decision in Alexander v. Sandoval significantly altered options for bringing an environmental justice claim. Several causes of action still remain, however, that can be an effective means of achieving environmental justice. This Article will explore these causes of action and show that each has unique characteristics and can present distinct opportunities. This Article will also address the importance of tailoring environmental justice claims to best suit the plaintiff. Finally, this Article will present a case study of a proposal to build a geothermal power plant in an area of California that is sacred to Native Americans, and suggest an effective strategy for bringing an environmental justice claim.