Saturday, May 4, 2013

Engine Manufacturers Association v. South Coast Air Quality Management District case brief

Engine Manufacturers Association v. South Coast Air Quality Management District case brief
541 U.S. 246 (2004)

CASE SYNOPSIS: Petitioner associations sued respondents, California's South Coast Air Quality Management District (District) and its officials, claiming that § 209 (42 U.S.C.S. § 7543) of the Clean Air Act (CAA), 42 U.S.C.S. § 7401 et seq., preempted six local Fleet Rules. The district court granted summary judgment to respondents, upholding the Rules in their entirety. The United States Court of Appeals for the Ninth Circuit affirmed. Certiorari was granted.

FACTS: The District enacted South Coast, Cal., Air Quality Mgmt. Dist. Fleet R. 1186.1, 1191, 1192, 1193, 1194, and 1196, which prohibited the purchase or lease by various public and private fleet operators of vehicles that did not comply with stringent emission requirements. The district court determined that § 209(a) of the CAA did not preempt these Fleet Rules, because they addressed the purchase of vehicles, rather than their manufacture or sale. However, the Court determined that at least certain aspects of the Fleet Rules were preempted. The text of CAA § 209(a) and the CAA's structure did not support the district court's manufacturer-specific interpretation of "standard" or the resulting distinction between purchase and sale restrictions. The Court found that the command, accompanied by sanctions, that certain purchasers could buy only vehicles with particular emission characteristics was as much an "attempt to enforce" a "standard" as a command, accompanied by sanctions, that a certain percentage of a manufacturer's sales volume had to consist of such vehicles.

CONCLUSION: The Court vacated the judgment and remanded the case for further proceedings.
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