"Winter involved a much more complicated procedural situation," he said. "The environmental community closely followed the Summers case because these groups often face this issue when trying to assert their own interests in a lawsuit."
Austin said he remained hopeful that the Summers decision will have a limited impact.
"It could have been much worse, but it was decided in a way that the consequences were not as bad as they could have been," he said. "The ruling was confined to the facts of that case and the specific plaintiffs. Even though [Justice Antonin] Scalia included a lot of language that was very dismissive of environmental groups, he did not adopt the very extreme position argued by the government."
PLF's Gieseler said he expects the Navy sonar decision will have more influence than some believe.
"There was a unique context in the sonar case -- national security -- but nothing that limited that holding to national security interests going forward," Gieseler said. "We're talking about an injunction that would impact the economy or other constitutional matters such as property. We don't see any reason that the principles underlying Winter wouldn't be applicable in these cases."
Meanwhile, the consolidated CERCLA cases could have an immediate impact on lower courts' decision-making, said John Nagle, an environmental law professor at the University of Notre Dame's law school.
"Burlington Northern was the most surprising given that the majority ended up addressing issues that the Supreme Court had never really addressed but had been thought to have been resolved by the lower courts decades ago," he said.
Earlier this month, the court announced it would hear a case concerning the private property rights of waterfront landowners in Florida when it begins a new term on Oct. 5.
In Stop the Beach Renourishment v. Florida, the justices will consider whether the state Supreme Court violated the Constitution's takings clause when it upheld a Florida government plan to create a state-owned public beach between private waterfront land and the Gulf of Mexico.
Meanwhile, opinion is mixed on whether the court's new term will feature as many high-profile environmental-themed cases.
"There might be a bit of a lull in activity, but as the new administration becomes more active in rule making, we will see more issues being litigated and they will eventually find their way to the Supreme Court," Nagle said.
Rather than environmental groups, which often initiated the lawsuits against Bush-era regulations, industry groups will begin opposing actions, especially as the Obama administration overturns rules, Kenna said.
"We're more likely to see regulated businesses being the ones looking for help at the court rather than the government simply because they'll be the ones challenging more of the policies of the Obama administration," he said.
In the next few terms, PLF's Gieseler suggested the court will likely consider cases involving global warming or, potentially, a cap-and-trade law.