Massachusetts v. Environmental Protection Agency (2006)
- Docket
- 05-1120
- Decided
- 2006-01-01
Summary
Question: 1) May the EPA decline to issue emission standards for motor vehicles based on policy considerations not enumerated in the Clean Air Act? 2) Does the Clean Air Act give the EPA authority to regulate carbon dioxide and other greenhouse gases? Conclusion: No and yes. By a 5-4 vote the Court reversed the D.C. Circuit and ruled in favor of Massachusetts. The opinion by Justice John Paul Stevens held that Massachusetts, due to its "stake in protecting its quasi-sovereign interests" as a state, had standing to sue the EPA over potential damage caused to its territory by global warming. The Court rejected the EPA's argument that the Clean Air Act was not meant to refer to carbon emissions in the section giving the EPA authority to regulate "air pollution agent[s]". The Act's definition of air pollutant was written with "sweeping," "capacious" language so that it would not become obsolete. Finally, the majority ruled that the EPA was unjustified in delaying its decision on the basis of prudential and policy considerations. The Court held that if the EPA wishes to continue its inaction on carbon regulation, it is required by the Act to base the decision on a consideration of "whether greenhouse gas emissions contribute to climate change." Chief Justice Roberts's dissenting opinion argued that Massachusetts should not have had standing to sue, because the potential injuries from global warming were not concrete or particularized (individual and personal). Justice Scalia's dissent argued that the Clean Air Act was intended to combat conventional lower-atmosphere pollutants and not global climate change.