Wednesday, January 30, 2013

Massachusetts v. Environmental Protection Agency case brief

Massachusetts v. Environmental Protection Agency case summary
549 U.S. 497 (2007)
Constitutional Law
 PROCEDURAL HISTORY: Petitioners, environmental organizations and state and local governments, brought an action challenging the determination of respondent Environmental Protection Agency (EPA) not to regulate motor vehicle emissions which allegedly contributed to global warming. Upon the grant of a writ of certiorari, petitioners appealed the judgment of the U.S. Court of Appeals for the District of Columbia Circuit which upheld EPA's determination.

- The EPA argued that the Clean Air Act (CAA) did not authorize the EPA to address global climate change and that, in any event, executive policy specifically addressing global warming warranted the EPA's refusal to regulate in such area.


-The U.S. Supreme Court first held that petitioners had standing to challenge EPA's denial of their rulemaking petition since at least one petitioner state properly asserted a concrete injury from the potential further loss of its coastal land, much of which was owned by the state, from rising sea levels caused by climate change.

-Further, because greenhouse gases were clearly within the CAA's broad definition of an air pollutant, the EPA had the statutory authority to regulate the emission of such gases from new motor vehicles, and there was no showing of any congressional intent to bar the EPA from addressing global warming.
-Also, it was undisputed that global warming threatened serious harms, and policy considerations were irrelevant to the EPA's statutory mandate to determine whether the greenhouse gases contributed to global warming and whether motor vehicle emissions of such gases actually or potentially endangered public health or welfare.


-The Clean Air Act defines "air pollutant" to include any air pollution agent or combination of such agents, including any physical, chemical, biological, radioactive substance or matter which is emitted into or otherwise enters the ambient air. § 7602(g). "Welfare" which may be endangered by pollution is also defined broadly: among other things, it includes effects on weather and climate.
-U.S. Const. art. III limits federal-court jurisdiction to cases and controversies.
-Those two words confine the business of federal courts to questions presented in an adversary context and in a form historically viewed as capable of resolution through the judicial process.
-It is therefore familiar learning that no justiciable controversy exists when parties seek adjudication of a political question, when they ask for an advisory opinion, or when the question sought to be adjudicated has been mooted by subsequent developments.

CONCLUSION: The judgment upholding EPA's determination to decline rulemaking was reversed, and the case was remanded for further proceedings.

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