Conservation Law Foundation, Inc. v. Shell Oil Products US, et al.

Summary

The United States District Court for the District of Rhode Island denies Defendants’ motion for reconsideration of the denial of their motion for partial summary judgment. The Court holds that Defendants’ evidence concerning a September 2025 Rhode Island Department of Environmental Management inspection was not newly discovered because Defendants possessed it during the pendency of their motion and failed to timely present it. The Court also states that, in any event, the inspection would not eliminate disputed facts concerning alleged environmental permit violations.

Holdings

1. Defendants were not entitled to reconsideration because they failed to demonstrate a manifest error of law or qualifying newly discovered evidence and failed to justify their delay in presenting the inspection evidence.
2. The RIDEM inspection evidence was not newly discovered because defendants possessed the evidence for several months while their summary-judgment motion was pending and deliberately or unjustifiably withheld it.
3. Even if considered, the RIDEM inspection would not warrant partial summary judgment because it constituted at most an additional disputed fact.

Questions Presented

1. Whether defendants established a manifest error of law or newly discovered evidence warranting reconsideration of the court's prior denial of partial summary judgment.
2. Whether evidence from the September 2025 RIDEM inspection could be treated as newly discovered when defendants possessed it for several months during the pendency of their summary-judgment motion.
3. Whether the RIDEM inspection independently required reconsideration of the prior summary-judgment ruling.

Disposition

other