Massachusetts v. Environmental Protection Agency

Brief Fact Summary.  The State of Massachusetts is suing the Environmental Protection Agency (EPA) for denial of their rulemaking petition in connection to regulation of green-house gases.

Synopsis of Rule of Law.  In order to have standing to sue in a federal court the petitioner must have; injury in fact, causation, and redressability in the claim, these elements are easier to meet if you are a State rather than an individual.

Facts. The coast of Massachusetts is in danger due to possible issues of global warming. In order to protect the State’s interest in the land on the coast, the State of Massachusetts petitions the EPA to regulate gas emissions from cars. There is much research to show such emissions add to green house gases that effect or cause global warming which in turn affects the water on the coast. The EPA denied the request. Now the State of Massachusetts is suing the EPA for not enforcing the Clean Air Act.

Issue.  Whether a State has standing to sue the EPA for not enforcing the Clean Air Act.

Held. Yes. In order to have standing a petitioner must have injury, causation and redressability. Typically the injury of green-house gases would be too tenuous for an individual to claim is a direct injury. However this is the State that is filing suit not the individual. The State has a quasi-sovereign interest.  The State has an interest in the land on its coast, and they have shown the injury of losing coastal property as the water rises. The State has also shown the casual connection, which the EPA does not deny, that global warming is a cause of the water rising.   As for redressability, that is shown as well. If the EPA regulates emissions from cars, that will help the issue of global warming in the State of Massachusetts. Since all requirements are shown, standing is proper.

Dissent. The issues of Global Warming are world wide; the injury claim does not meet the particularity requirements of standing. The injury is too big, and redressability needs to come from the legislature not the bench.

Discussion.  The EPA stresses that even if they help the State of Massachusetts, it will not actual combat the issue of global warming. In order to have a proper effect they would need to regulate the entire United States, and then because of China and India their efforts would not amount to much. However the EPA misses the point of what standing is for; standing is the right to bring suit against a party, not to decide the end result of that law suit.