Massachusetts v. EPA

Brief Fact Summary.

The plaintiffs sued the EPA, arguing that its failure to regulate motor vehicle emissions violated the Clean Air Act. The EPA argued that Plaintiffs  lacked standing.

Synopsis of Rule of Law.

Under Supreme Court precedent, and as articulated in Lujuan, a claimant must show that she has suffered a concrete and particularized injury that is actual or imminent, that the injury is fairly traceable to the defendant, and that it is likely that a favorable decision will redress that injury.

The Court cited Georgia v. Tennessee Copper Co., 206 U.S. 230, 237 (1907), to show that states are entitled to special solicitude in standing analyses because they have quasi-sovereign interests.

Facts.

Section 202(a)(1) of the Clean Air Act provides that the EPA Administrator shall regulate emissions of air pollutants from new motor vehicles or new motor vehicle engines that cause or contribute to air pollution that might endanger public health or welfare. 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. The EPA argued that Plaintiffs lacked standing.

Issue.

Did the plaintiffs have standing?

Held.

Yes, the plaintiffs had standing. Case reversed and remanded.

Dissent.

Justice Roberts, joined by Justice Scalia, Justice Thomas, and Justice Alito

Justice Roberts argued that there is no basis for granting state claimants special solicitude in standinganalyses. He also argued that the evidence the plaintiffs presented to establish their injury was merely conjecture, and that the injury was not imminent. He also found that the asserted causation between the EPA’s decision not to regulate emissions of new motor vehicles and the injury 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.

Massachusetts was entitled to special solicitude in the Court’s standing analysis, because it was seeking to preserve its sovereign territory. Additionally, Plaintiffs satisfied the standing requirements articulated in Lujan. The court cited a report and expert testimony on the general harms of climate change to show that there was an injury. Massachusetts also suffered concrete injury, because climate change was causing its coastline to recede. The fact that the harms of climate change are widely shared did not reduce Massachusetts’ interest in the litigation.

The EPA argued that the plaintiffs did not show causation, because its decision not to regulate new motor vehicles contributed insignificantly to the plaintiffs’ injuries, especially where emissions from other countries might offset domestic decreases. The Court disagreed and found that there was causation, because the fact that a step might be incremental does not mean that federal courts lack jurisdiction over that step.

Finally, the Court held that a favorable decision could redress Plaintiffs’ injury, because it could slow or reduce climate change. It did not matter that a favorable decision alone might not reverse climate change entirely.