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Environmental Justice Update: DOJ Releases Inaugural EJ Enforcement Strategy Report

The Comprehensive Environmental Justice Enforcement Strategy Annual Report builds on the DOJ’s creation of its Office of Environmental Justice within the DOJ’s Environment and Natural Resources Division (ENRD), which has...more

Supreme Court Could Open the Door to “Regulatory Takings” Challenges to Regulations

The US Supreme Court has announced it will evaluate whether “impact fees” associated with permits can violate the Fifth Amendment to the US Constitution. At stake is the determination of when, how, and under what...more

Environmental Justice Update: EPA Provides Toolkit to State and Local Governments on Community Engagement

Sometimes where to begin is the hardest part. The US Environmental Protection Agency’s (EPA) recently released Toolkit is intended to help local and state governments start their environmental justice (EJ) journey through...more

Environmental Justice Update: EPA Publishes Cumulative Risk Assessment Comments

While increased enforcement resulting from increased federal focus on environmental justice (EJ) issues poses risk to many businesses, how (and perhaps whether) the US Environmental Protection Agency (EPA) assesses and...more

California Court Rejects CERCLA Apportionment Defense in Cleanup Case

“Joint and several” liability for environmental remediation costs is fundamental to the federal Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). In general, CERCLA incorporates “joint and...more

Environmental Justice Update: Louisiana Decision Upholds Use of EPA Emergency Powers

Louisiana has been at the center of the Biden Administration’s prioritization of environmental justice (EJ) issues. In United States v. Denka Performance Elastomer, the Eastern District of Louisiana granted a motion by the...more

Is Environmental Justice at a Crossroads? Three Issues to Watch in Fall 2023

More so than any other issue, environmental justice (EJ) remains a central pillar of the Biden Administration’s regulatory agenda. Below, we’ll answer three EJ-related questions that the regulated community may struggle with...more

Three Environmental Trends Illustrated by Montana Kids’ Climate Decision

One might not expect that a climate-change case filed by a group of children could succeed. This week, a Montana state court decision in this summer’s hottest climate-focused case, Held v. State of Montana, finding in...more

Fourth Circuit Holds Catch-and-Release Fishing Not Regulated by Federal Clean Water Act

The “Major Questions Doctrine” (MQD) has been the breakout star of the last two terms at the US Supreme Court. Earlier this month, the Fourth Circuit used MQD in upholding the dismissal of a nongovernmental organization’s...more

Biden Administration Proposes Significant Changes to Regulations Implementing the National Environmental Policy Act

The energy transition and increased public focus on environmental issues have strained the existing regulatory regime including the National Environmental Policy Act (NEPA). NEPA directs agencies to conduct environmental...more

Biden Administration Releases New Guidance Seeking to Broaden Public Participation and Community Engagement

]Effective and meaningful public engagement are “foundational principles of Federal regulatory development” and the Biden Administration has sought to remove barriers to public participation in the regulatory process. We...more

Administrative Law Update: Status Update on Federal OMB’s Proposed Revisions to Circular A-4

The Biden Administration is in the process of revising a cog fundamental to federal policymaking. The cog, a guidance document issued by the Office of Management and Budget’s (OMB) entitled Circular A-4, has the potential to...more

ESG Update: The New ISSB Standards Focus on Financial Materiality

The International Sustainability Standards Board (ISSB) standards have joined the climate-disclosure reporting frameworks that take a financial materiality-led approach. While the ISSB standards seek to streamline reporting...more

SCOTUS Update: Administrative Law Takeaways from Biden v. Nebraska

Last week, the US Supreme Court ruled that the Biden Administration’s efforts to cancel $430 billion in student loan balances was legally unsupportable. Forty-three million Americans will remember Biden v. Nebraska when...more

Will Environmental Justice Programs Be Affected by SCOTUS’s Affirmative Action Decisions?

In the United States, environmental and public health measures often correlate to variables like education, income, and a community’s racial makeup. In the five decades since Congress began to create comprehensive...more

DC Circuit Scrutinizes Federal Regulations for Explicit Statutory Hook Even When No “Major Questions” Are Involved

A DC Circuit decision related to the US Environmental Protection Agency’ (EPA) hydroflurocarbons (HFC) phase out illustrates that federal regulations face significant scrutiny when reviewed in court even where the regulations...more

ESG Update: Greenwashing Litigation Filed over Airline’s Carbon Neutrality Claims

A group of Delta Air Lines’ customers filed a class action suit alleging that the airline’s marketing claims of carbon neutrality are false and misleading. While this may be the first greenwashing case filed against a major...more

Environmental Justice Update: Differing State and Local Approaches to Federal Civil Rights Actions

Addressing environmental justice (EJ) issues has been a primary concern for the Biden Administration. Recent developments — one in Chicago and one in Louisiana — show different ways local and state regulators have reacted to...more

Supreme Court Issues Decision in Sackett v. EPA Rolling Back Clean Water Act Jurisdiction Over Certain Wetlands

In a closely watched environmental Clean Water Act (CWA) case, the US Supreme Court adopted a far narrower construction of CWA’s definition of “waters of the United States,” functionally shifting significant authority over...more

Supreme Court Pulls Back Dormant Commerce Clause in National Pork Producers Council v. Ross

Federalism — the allocation between federal and state governments — is at the heart of American constitutional law. In a dispute related to the constitutionality of California state regulations dealing with pig farming, the...more

Four Administrative Law Takeaways from the DC Circuit’s Recent Perchlorate Decision

Crafting environmental regulations often takes time and substantive knowledge about complex technical and policy issues. Below, we draw some key administrative law takeaways from the DC Circuit’s May 9 decision in National...more

ESG Update: NGOs Push Substantive Policy Agendas in Comments to FTC’s “Green Guides”

In recent years, “sustainability” has gone from being a niche product approaching, in some quarters, a religion. Few would argue with the proposition that issues like climate- and carbon-neutrality and recyclability have...more

Supreme Court to Establish Whether the “Chevron Doctrine” Deserves a Tombstone

The “Chevron doctrine,” meaning whether courts should defer to agency interpretations of ambiguous statutes they administer, has been viewed as a key underpinning of the modern regulatory state. Repeatedly for nearly a...more

Environmental Justice Update: New Biden Administration Executive Order Expands EJ Across Federal Government; New Jersey Rolls Out...

If you blink, there’s a good chance that you will miss a major development in the environmental justice (EJ) space. Given that Earth Day occurred last week, it’s no surprise we have two major developments to report: ...more

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