Massachusetts v. EPA

Brief Fact Summary.

The plaintiffs sued the EPA, arguing that its failure to regulate emissions violated the Clean Air Act.

Synopsis of Rule of Law.

A state can have show injury and standing to sue the EPA for violating its obligations under the Clean Air Act.

Facts.

The Clean Air Act required the EPA to regulate certain emissions. The plaintiffs, calling global warming “the most pressing environmental challenge of our time,” sued the EPA, arguing that its failure to regulate motor vehicle emissions violated the Clean Air Act.

Issue.

Did the petitioners show an injury to have standing to sue the EPA?

Held.

Yes, the petitioners showed an injury and had standing to sue the EPA.

Dissent.

Justice Roberts

Justice Roberts argued that the Court weighed the fact that Massachusetts had quasi-sovereign interests too heavily in their favor. He also argued that the injury was not imminent, and that the asserted causation was too speculative, because climate change has many causes. Finally, Justice Roberts argued that a favorable decision was not likely to redress plaintiffs’ injury.

Discussion.

In Lujan v. Defenders of Wildlife, the Court held that claimants must show they have suffered a concrete and particularized injury that is actual or imminent, and fairly traceable to the defendant, and that it is likely that a favorable decision will redress that injury.

According to the Court, Massachusetts was entitled special solicitude in this analysis, in part because it had a stake in protecting its quasi-sovereign interests.

The Court cited the harms of climate change, including rising sea levels that were already encroaching on Massachusetts’ coastal land. The Court also cited evidence to argue that the EPA’s refusal to regulate carbon emissions contributed to Massachusetts’ injuries. The Court held that petitioners had standing to sue the EPA, because their harm would be reduced if they were granted the relief they sought.