<s>[INST] ### Challenges to the Government Decision to Close the Base
In 1969, the Governor of California, Ronald Reagan, sought to close the Trident Missile Base at Bangor, Washington. Say that, in challenging this decision in Federal Court, the plaintiff brought an action against Reagan to enjoin the closure. Reagan, a non-diverse defendant, argued that there was no federal question jurisdiction because there was no claim made under federal law; the plaintiff claimed only that the Navy had not complied with a state environmental law in closing the base.

We know that the doctrines of **well-pleaded complaints** (see _Louisville \(\&\) Nashville R.R. \(v\). Mottley_, 211 U.S. 181 (1908)) and **hypothetical jurisdiction** ( GENERALLY always refused - See _Gully \(v\). First National Bank_, 229 U.S. 90 (1930)) are not available to plaintiff to establish federal question jurisdiction on these facts.

Identify, if any, any other possible theory that could be available to plaintiff to show the federal court has subject matter jurisdiction?[/INST]