Massachusetts v. E.P.A. , 127 S.Ct. 1438 (2007) . Chevron Analysis. Background. The Court has determined that the plaintiffs have standing.
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 In concluding that it lacked statutory authority over greenhouse gases, EPA observed that Congress "was well aware of the global climate change issue when it last comprehensively amended the [Clean Air Act] in 1990," yet it declined to adopt a proposed amendment establishing binding emissions limitations. Id., at 52926. Congress instead chose to authorize further investigation into climate change.
EPA further reasoned that Congress' "specially tailored solutions to global atmospheric issues," 68 Fed. Reg. 52926 -- in particular, its 1990 enactment of a comprehensive scheme to regulate pollutants that depleted the ozone layer -- counseled against reading the general authorization of §202(a)(1) to confer regulatory authority over greenhouse gases.
 EPA reasoned that climate change had its own "political history": Congress designed the original Clean Air Act to address local air pollutants rather than a substance that "is fairly consistent in its concentration throughout the world's atmosphere," declined in 1990 to enact proposed amendments to force EPA to set carbon dioxide emission standards for motor vehicles, ibid. and addressed global climate change in other legislation, 68 Fed. Reg. 52927.
Background: Property owners brought action, individually and on behalf of all persons similarly situated, against oil companies, asserting public and private nuisance, trespass, and negligence claims based on oil companies' alleged release of by-products that increased global warming, led to development of conditions that formed hurricanes and resulted in higher insurance premiums, and caused sea level to rise. Oil companies filed motions to dismiss.
Holdings: The District Court, Louis Guirola, Jr., Chief Judge, held that:
1 doctrines of res judicata and collateral estoppel barred the action;
2 owners lacked standing to assert global warming claims;
3 owners' claims presented non-justiciable political questions;
4 the Clean Air Act preempted owners' state law claims;
5 Mississippi's savings statute did not apply so as to permit property owners to file new action asserting their time-barred claims;
6 owners' claims pertaining to future risk of more severe storms and loss of property were not vested; and
7 companies' emissions were too remote to be proximate cause of owners' damages.