Stephen Jones, et al. v. Perdue Farms Inc., et al.

Summary

The United States District Court for the District of Maryland denied Plaintiffs Stephen Jones and Richard Renshaw’s motion for reconsideration of an earlier order addressing their Resource Conservation and Recovery Act claims against Perdue entities. The court held that Plaintiffs had not shown clear error causing manifest injustice in the prior conclusions concerning environmental standing and pleading an imminent and substantial endangerment under 42 U.S.C. § 6972(a)(1)(B). The court also determined that Trinity American Corp. v. EPA was not dispositive because it involved a different statute and had not been cited during the original briefing.

Holdings

1. Reconsideration was not warranted because plaintiffs identified neither substantially different evidence nor an intervening change in law and failed to show clear error causing manifest injustice.
2. Plaintiffs could not seek relief through a substantive claim based on environmental harms for which they had not established standing.
3. Plaintiffs did not demonstrate clear error warranting reconsideration because they failed to allege that they or anyone else was drinking or otherwise using the contaminated water, and the principal authority they relied on involved a different statute.

Questions Presented

1. Whether the court should reconsider its prior interlocutory dismissal under Federal Rule of Civil Procedure 54(b) based on clear error causing manifest injustice.
2. Whether plaintiffs who failed to plead environmental standing could rely on alleged environmental harms to support an RCRA imminent-and-substantial-endangerment claim.
3. Whether allegations that plaintiffs' drinking water was contaminated, without allegations that plaintiffs or others were drinking or otherwise using the water, sufficiently pleaded an imminent and substantial endangerment to health under 42 U.S.C. § 6972(a)(1)(B).

Disposition

other