Summary
The Supreme Court held that fuel producers have Article III standing to challenge the Environmental Protection Agency's approval of California vehicle-emissions and electric-vehicle regulations. The Court reversed the judgment of the D.C. Circuit and remanded for consideration of the fuel producers' underlying legal claims.
Topics
Practice areas
Questions Presented
- Whether fuel producers have Article III standing to challenge EPA's approval of California's vehicle-emissions regulations based on asserted monetary injury from reduced fuel demand.
- Whether the fuel producers established redressability when relief would affect their injury through the predictable responses of third-party automakers and consumers.
- Whether plaintiffs must submit affidavits or other evidence from expert economists or directly regulated third parties to establish a predictable chain of events for redressability.
Holdings
- The fuel producers established injury in fact and causation because the regulations likely reduce purchases of gasoline and other liquid fuels, thereby causing monetary injury to businesses that sell those fuels.
- The fuel producers established Article III redressability because setting aside EPA's approval would likely lead to increased production of gasoline-powered vehicles, increased fuel purchases, and at least some additional revenue for the producers.
- Plaintiffs need not provide affidavits or testimony from expert economists or directly regulated third parties to establish redressability; they must show a predictable chain of events that would likely result from judicial relief and redress the injury.
- A permanently and dramatically changed market might, in an atypical case, make invalidation unable to redress an injury, but courts should be cautious before denying standing on speculative claims that invalidating an important regulation would have zero effect in a dynamic, heavily regulated market.
Key quotations
“Based on this Court's precedents and the evidence in the record, we hold that the fuel producers have standing.” (105)
“Rather, to show redressability, the plaintiff must simply "show a predictable chain of events" that would likely result from judicial relief and redress the plaintiff's injury.” (121)
“The government generally may not target a business or industry through stringent and allegedly unlawful regulation, and then evade the resulting lawsuits by claiming that the targets of its regulation should be locked out of court as unaffected bystanders.” (125)
Factual background
EPA approved California regulations requiring automakers to reduce average greenhouse-gas emissions across new-vehicle fleets and manufacture a specified percentage of electric vehicles. California and 17 other States adopted some or all of the regulations. Fuel producers submitted declarations that the regulations would reduce gasoline and other liquid-fuel demand, causing monetary injury, and that invalidation would likely increase fuel sales. The D.C. Circuit found the asserted redressability theory insufficient because the producers had not shown that automakers would likely change their production decisions after invalidation.
Procedural history
After EPA reinstated approval of California's greenhouse-gas and electric-vehicle regulations in 2022, fuel producers challenged the approval under the Clean Air Act. The D.C. Circuit held that the producers had not shown that vacatur would likely cause automakers to produce more gasoline-powered vehicles and therefore dismissed for lack of standing. The Supreme Court reversed and remanded for consideration of the merits.
Remand instructions
The D.C. Circuit was directed to consider the merits of the fuel producers' legal claims challenging EPA's approval of the California regulations.