{"id":3499,"date":"2015-08-25T14:15:44","date_gmt":"2015-08-25T19:15:44","guid":{"rendered":"http:\/\/blogs.law.columbia.edu\/climatechange\/?p=3499"},"modified":"2017-02-28T09:32:10","modified_gmt":"2017-02-28T14:32:10","slug":"lawsuit-alleges-that-u-s-government-violated-constitutional-rights-of-americas-youth-by-promoting-the-development-and-use-of-fossil-fuels","status":"publish","type":"post","link":"https:\/\/blogs.law.columbia.edu\/climatechange\/2015\/08\/25\/lawsuit-alleges-that-u-s-government-violated-constitutional-rights-of-americas-youth-by-promoting-the-development-and-use-of-fossil-fuels\/","title":{"rendered":"Lawsuit Alleges that U.S. Government Violated Constitutional Rights of America\u2019s Youth by Promoting the Development and Use of Fossil fuels"},"content":{"rendered":"
<\/div>

\"our<\/a>By Nikita Perumal and Jessica Wentz<\/p>\n

A foundational component of sustainable development is the principle of inter-generational equity: that we should meet the needs of the present without compromising the ability of future generations to meet their own needs.<\/p>\n

On August 12, a group of twenty-one youths invoked this principle in a lawsuit filed against the federal government in the U.S. District Court in Oregon. The complaint<\/a> alleged that the federal government has violated \u201cthe fundamental right of citizens to be free from government actions that harm life, liberty, and property\u201d by \u201capproving and promoting fossil fuel development, including exploration, extraction, production, transportation, importation, exportation, and combustion.\u201d[1]<\/a><\/p>\n

The non-profit Our Children\u2019s Trust<\/a>, which helped file the complaint for declaratory and injunctive relief, explains on its website<\/a> that \u201c[p]laintiffs seek to hold President Obama and various federal agencies responsible for continued fossil fuel exploitation. The Federal Government has known for decades that fossil fuels are destroying the climate system.\u201d Thus, according to Julia Olson<\/a>, lead counsel on the case and public interest attorney for Our Children\u2019s Trust, \u201cthis lawsuit asks whether our government has a constitutional responsibility to leave a viable climate system for future generations?”<\/p>\n

<\/p>\n

 <\/p>\n

Summary of the Complaint<\/em><\/strong><\/p>\n

\u00a0<\/em><\/strong>The complaint in Kelsey Cascadia Rose Juliana, Xiuhtezcatl Tonatiuh M. et al. v. United States, Barack Obama et al. <\/em>cites several constitutional violations arising from the federal government\u2019s continued promotion and use of fossil fuels. The specific allegations include:<\/p>\n

Fifth Amendment Due Process Clause:<\/strong> The federal government has violated the plaintiffs\u2019 substantive due process rights by allowing atmospheric CO2<\/sub> levels to reach levels that endanger the lives, liberty, and property of the youth defendants and future generations.<\/p>\n

Fifth Amendment Equal Protection:<\/strong> The federal government has denied plaintiffs and future generations the same protection of fundamental rights afforded to prior and present generations of adult citizens. In particular, Section 201 of the 1992 Energy Policy Act is unconstitutional due to its mandatory authorization for export and import of natural gas (which \u201cdiscriminates against Plaintiffs by exacerbating already-dangerous levels of atmospheric CO2<\/sub>\u2026 the consequences of which will be irreversible and catastrophic in Plaintiffs\u2019 lifetimes\u201d).[2]<\/a> Moreover, because climate change poses a \u201cgrave and continuing harm to children,\u201d the plaintiffs should be treated as a protected class and the court should apply strict scrutiny when reviewing the Equal Protection claim.[3]<\/a><\/p>\n

Unenumerated Rights Preserved by the Ninth Amendment:<\/strong> The \u201cright to be sustained by our country\u2019s vital natural systems, including our climate system\u201d is one of the \u201cimplicit liberties protected from government intrusion by the Ninth Amendment.\u201d[4]<\/a> Federal defendants have violated this right by contributing to dangerous levels of atmospheric and oceanic CO2<\/sub> and a destabilized climate system.<\/p>\n

The Public Trust Doctrine:<\/strong> Plaintiffs are \u201cbeneficiaries of rights under the public trust doctrine, rights that are secured by the Ninth Amendment and embodied in the reserved powers doctrines of the Tenth Amendment and the Vesting, Nobility, and Posterity Clauses of the Constitution.\u201d[5]<\/a> Federal defendants have violated their public trustee obligations by contributing to the destruction of the climate system\u2014a vital natural resource for present and future generations.<\/p>\n

Climate scientist James Hansen, who will serve as guardian to 17-year-old plaintiff Sophie Kivlehan and to \u201cFuture Generations\u201d in the case, notes in an expert declaration<\/a> supporting the case that \u201cin [his] opinion, this lawsuit is made necessary by the at-best schizophrenic, if not suicidal, nature of U.S. climate and energy policy.\u201d To amend for such policy, the complaint requests injunctive relief through a court order that would require \u201c[d]efendants to swiftly phase-down CO2<\/sub> emissions aimed at atmospheric CO2<\/sub> concentrations that are no more than 350 ppm by 2100, develop a national plan to restore Earth\u2019s energy balance, and implement that national plan so as to stabilize the climate system.\u201d[6]<\/a> The complaint also requests that the administration prepare a consumption-based inventory of CO2 <\/sub>emissions in the United States.<\/p>\n

The case singles out the recent federal approval of the Jordan Cove Liquefied Natural Gas (LNG) energy project<\/a> proposal in Coos Bay, Oregon, which serves as a specific and local example of a fossil fuel extraction project that would infringe on the plaintiffs\u2019 constitutional rights. In the press release<\/a> by Our Children\u2019s Trust, 18-year-old plaintiff and Oregon resident Alex Loznak detailed his injury with respect to the Jordan Cove project:<\/p>\n

\u201cBy 2020, [the project] will be the largest emitter of greenhouse gases in the whole state of Oregon. Science tells us we must sharply cut back on CO2<\/sub> emissions, but my Federal Government has given the green light to massive LNG exports from this terminal. If constructed, the terminal would process one billion cubic feet of natural gas per day, locking us into dependence on fossil fuels at a time when we should be transitioning toward a renewable energy economy. My family has owned a farm near the proposed pipeline route for almost 150 years, and I\u2019m worried about the impacts that increased drought and wildfire will have on the farm unless we act now on climate change.\u201d<\/p>\n

Ms. Olson asserted in the same press release that \u201c[t]he Federal Government has consciously chosen to endanger young people\u2019s right to a stable climate system for the short-term economic interests of a few. In light of the established science, federal approval of the Jordan Cove LNG Project cannot stand.\u201d Accordingly, the complaint\u2019s Prayer for Relief requests that the court declare unconstitutional both Section 201 of the Energy Policy Act (which mandates the authorization of natural gas imports from and exports to nations with which the U.S. has a free trade agreement) and the DOE\/FE order granting authorization for the Jordan Cove project.<\/p>\n

In addition to the injuries specific to the Jordan Cove project, a significant portion of the 96-page complaint is dedicated to enumerating the specific ways in which the plaintiffs\u2019 rights to life, liberty, and property will be adversely affected by climate change. The text establishes that the plaintiffs, as young people, are \u201cespecially vulnerable to the dangerous situation that Defendants have substantially caused.\u201d[7]<\/a> It elaborates the livelihoods, environments, and injuries of the 21 youths in great detail. 18-year-old Jacob Lebel, for instance, \u201cis harmed and will continued to be harmed\u201d by the defendants\u2019 actions because climate change will contribute to the deterioration of the farm on which he works and intends to pursue a livelihood.[8]<\/a> Similarly, Zealand Bell, 11, has been negatively impacted by increased drought, heat waves, and warmer temperatures, which have threatened \u201chis enjoyment of outdoor activities\u201d and have resulted in lost income, as his mother\u2019s seasonal job at a ski resort was not available in 2014 due to lack of snow.[9]<\/a> Sahara Valentine, also 11, has experienced several asthma attacks from the increased frequency of forest fires in Oregon (a result of hotter and drier temperatures).<\/p>\n

In a statement<\/a> to The Huffington Post<\/em>, EPA deputy press secretary Laura Allen responded to the complaint with a reference to the EPA\u2019s current work on climate change:<\/p>\n

\u201cThat’s why President Obama launched the Climate Action Plan and why EPA is taking action with our Clean Power Plan: to give our kids and grandkids the cleaner, safer future they deserve. We have a moral obligation to leave a healthy planet for future generations \u2026 A child born today will turn fifteen in the year 2030 \u2013 the year when the full benefits of the Clean Power Plan will be realized.\u201d<\/p>\n

The complaint itself, however, cites the Clean Power Plan as \u201canother example of EPA\u2019s failure to even seek future CO2<\/sub> emissions reductions at anything near the rate required to preserve a habitable climate system.\u201d[10]<\/a> The plaintiffs thus indict the plan as insufficient\u2014it only impacts emissions from the power sector, encourages reliance on natural gas, does not otherwise diminish fossil fuel extraction in the United States, and \u201cdoes not even return U.S. emissions to 1990 levels.\u201d[11]<\/a><\/p>\n

 <\/p>\n

Legal Hurdles<\/em><\/strong><\/p>\n

This preliminary complaint will no doubt face certain hurdles as it proceeds.<\/p>\n

Standing – <\/strong>One threshold issue is whether the plaintiffs have standing to bring the suit. To demonstrate standing, plaintiffs must show that they have suffered a concrete and particularized injury that is either actual or imminent, that the injury is fairly traceable to the challenged action, and that it is likely\u2014as opposed to merely speculative\u2014that a favorable court decision will redress the injury.<\/p>\n

The \u201cparticularized injury\u201d requirement is one potential barrier to lawsuits alleging injuries from climate change and other widespread environmental harms.[12]<\/a> The Supreme Court has held that, to satisfy this requirement, plaintiffs must show that they are injured in a \u201cpersonal and individual way and that they seek relief that will \u201cdirectly and tangibly\u201d benefit them in a manner distinct from its impact on \u201cthe public at large.\u201d[13]<\/a><\/p>\n

As noted above, the complaint in this case goes into great detail about the specific injuries suffered by the youth plaintiffs, and this may be sufficient for the purpose of demonstrating particularized injury. However, given that there are many similarly situated persons who will suffer similar injuries, the court may conclude that these are \u201cgeneralized grievances\u201d and that the \u201cimpact on [the plaintiffs] is plainly undifferentiated and common to all members of the public.\u201d[14]<\/a><\/p>\n

Plaintiffs may also have difficulty establishing that their injuries are fairly traceable to federal defendants\u2019 actions and omissions, and correspondingly, that a favorable decision could redress those injuries. Establishing a causal connection in this context will likely require a showing that greenhouse gas (GHG) emissions from the allegedly unconstitutional behavior constitute a \u201cmeaningful\u201d or \u201csignificant\u201d contribution to global GHG levels. For example, in Massachusetts v. EPA<\/a> <\/em>(2007), <\/em>the Supreme Court held that Massachusetts had standing to challenge EPA\u2019s failure to regulate GHG emissions from the transportation sector because the record indicated that the U.S. transportation sector \u201cemits an enormous quantity of carbon dioxide into the atmosphere\u201d and these emissions did in fact \u201ccontribute\u201d to the adverse impacts of climate change on the state.[15]<\/a><\/p>\n

Several years later, in Washington Environmental Council v. Bellon<\/a><\/em> (2013), the U.S. Court of Appeals for the Ninth Circuit held that two non-profits did not have standing to challenge Washington State\u2019s failure to regulate GHG emissions from five oil refineries, because they had not shown that the refineries\u2019 emissions made a \u201cmeaningful contribution to global GHG levels.\u201d[16]<\/a> As such, plaintiffs had not established an adequate causal connection between those emissions and the alleged injuries resulting from the adverse impacts of climate change.<\/p>\n

Similarly, in Kivalina v. ExxonMobil Corporation<\/a> <\/em>(2009), <\/em>the U.S. District Court for the Northern District of California held that the Inupiat village of Kivalina lacked standing to sue oil, energy, and utility companies for public nuisance based on their GHG emissions. Specifically, the court held that Kivalina had not demonstrated that its injuries were \u201cfairly traceable\u201d to the defendants\u2019 actions. The court noted that there were a \u201cmultitude of \u2018alternative culprit[s]\u2019 allegedly responsible for the various chain of events allegedly leading to the erosion of Kivalina.\u201d[17]<\/a> But as noted below, this case was ultimately affirmed on different grounds (the federal common law claims had been legislatively displaced by the Clean Air Act).<\/p>\n

Political Question – <\/strong>A second threshold issue is whether plaintiffs have raised a non-justiciable political question. The District Court in Kivalina <\/em>asserted that, in addition to a lack of standing, the political question also barred review of the case. The court explained that plaintiffs had raised a political question because: (i) there was insufficient guidance as to the principles or standards that should be employed to resolve the claims at issue,[18]<\/a> and (ii) resolving Kivalina\u2019s nuisance claim would require the court to make decisions that are better left to the executive or legislative branch in the first instance, such as defining an acceptable limit on GHG emissions from the energy producers.[19]<\/a><\/p>\n

However, the political question doctrine has not prevented the Supreme Court and other federal courts from reviewing climate change-related claims. The Supreme Court did not explicitly analyze this issue in Massachusetts v. EPA<\/a> <\/em>(2007) or American Electric Power v. Connecticut<\/a> <\/em>(2011). But in American Electric Power<\/em>, the Court did note that there was no \u201cthreshold obstacle\u201d that barred review of a federal common law nuisance claim against major GHG emitters. In making this statement, the Court cited the defendants\u2019 political question argument, which had already been rejected by the Second Circuit Court of Appeals.[20]<\/a> The Second Circuit decision<\/a> addressed the political question argument in depth and concluded that none of the Baker<\/em> factors[21]<\/a> would bar review of a federal common law claim alleging nuisance as a result of GHG emissions.[22]<\/a><\/p>\n

Displacement – <\/strong>The Supreme Court ultimately decided in favor of the defendants in American Electric Power<\/em>, holding that the federal common law claims had been legislatively displaced by the Clean Air Act and its authorization for EPA to regulate GHG emissions. [23]<\/a> Following this decision, the Ninth Circuit Court of Appeals affirmed the Kivalina<\/em> decision<\/a> for the same reason (without discussing the validity of the lower court\u2019s interpretation of standing requirements and the political question doctrine).[24]<\/a><\/p>\n

In the present case, plaintiffs have alleged violations of constitutional law rather than federal common law. Although the doctrine of displacement does not apply to constitutional claims, the Supreme Court’s determination that the field of GHG regulation is now “occupied” because the Clean Air Act authorizes EPA to decide when and how to regulate such emissions may influence the court’s analysis of whether plaintiffs have raised a political question that should be resolved by the executive and legislative branches.<\/p>\n

Constitutional Claims – <\/strong>Even if the case survives these initial hurdles, the plaintiffs may have difficulty succeeding on the merits.<\/p>\n

Their public trust claim will likely be dismissed in light of recent case law. Take, for example, the Supreme Court\u2019s decision in PPL Montana, LLC. V. Montana<\/a><\/em> (2013), where Justice Kennedy wrote that \u201cthe public trust doctrine remains a matter of state law\u201d and that \u201cthe contours of that public trust do not depend upon the Constitution.\u201d[25]<\/a> This statement may have been dictum, but has nonetheless been treated as controlling precedent. In Alec L. v. Jackson<\/a><\/em> (2012), another suit brought by Our Children\u2019s Trust, a U.S. District Court for the District of Columbia cited this language when dismissing a lawsuit alleging that the federal government had violated its obligations as a public trustee by failing to reduce GHG emissions.[26]<\/a> The D.C. Circuit Court of Appeals affirmed this decision last year.[27]<\/a><\/p>\n

With respect to Substantive Due Process claims, the Supreme Court has held that the asserted fundamental liberty interest must be \u201cdeeply rooted in [our] Nation\u2019s history and tradition\u201d and that the judicial analysis must begin with \u201ccareful description\u201d of the asserted right (since courts \u201cmust exercise the utmost care [when] asked to break new ground in this field\u201d).[28]<\/a> In this case, the plaintiffs allege an injury to their \u201cdignity, including their capacity to provide for their basic human needs, safely raise families, practice their religious and spiritual beliefs, maintain their bodily integrity, and lead lives with access to clean air, water, shelter, and food.\u201d[29]<\/a> While many of these rights may qualify as fundamental liberty interests under the Supreme Court\u2019s test, the courts have been very slow to declare Substantive Due Process rights. Moreover, in the few cases where courts have found a violation of Substantive Due Process rights, it has been in the context of affirmative government action that directly and purposively restricted private behavior in a manner which abridged the rights of certain groups.[30]<\/a> In the present case, the connection between the federal defendants\u2019 behavior and the violation of the rights is more tenuous.<\/p>\n

Although the plaintiffs do not explicitly refer to a \u201cright to a clean environment,\u201d it is worth noting that the federal courts have yet to infer such a right from the constitution. In Environmental Defense Fund v. Corps of Engineers of U.S. Army<\/a> <\/em>(1971), a District Court in Arkansas concluded that such a right was not protected under the 5th, <\/sup>9th<\/sup>, and 14th<\/sup> Amendments. The court explained:<\/p>\n

Those who would attempt to protect the environment through the courts are striving mightily to carve out a mandate from the existing provisions of our Constitution. Others have proposed amendments to our Constitution for this purpose. \u2026 Such claims, even under our present Constitution, are not fanciful and may, indeed, some day, in one way or another, obtain judicial recognition. But, as stated by Judge Learned Hand in Spector Motor Serv., Inc. v. Walsh, 139 F.2d 809 (2 Cir., 1944):<\/em><\/p>\n

\u2018Nor is it desirable for a lower court to embrace the exhilarating opportunity of anticipating a doctrine which may be in the womb of time, but whose birth is distant.\u2019<\/em><\/p>\n

The Ninth Amendment may well be as important in the development of constitutional law during the remainder of this century as the Fourteenth Amendment has been since the beginning of the century. But the Court concludes that the plaintiffs have not stated facts which would under the present state of the law constitute a violation of their constitutional rights\u2026 The Court’s decision on this point gives further emphasis to its statement, supra, that final decisions in matters of this type must rest with the legislative and executive branches of government<\/em>.[31]<\/a><\/p>\n

Similar decisions have been issued in the Fourth Circuit[32]<\/a> and by district courts in New York[33]<\/a> and Texas.[34]<\/a><\/p>\n

Notably, although the courts have not yet held that the constitution includes an implicit right to a clean environment, the decisions in Environmental Defense Fund v. Corps of Engineers<\/em> and other cases did suggest that a right may be forthcoming. However, it is extremely unlikely that our Supreme Court would support such a novel interpretation of the constitution at this time.<\/p>\n

 <\/p>\n

Other Legal Developments<\/em><\/strong><\/p>\n

Our Children\u2019s Trust has been active in coordinating other youth-led climate law cases, such as the recently decided case Zoe & Stella Frazier v. Washington Department of Ecology<\/em><\/a>, where the Supreme Court of Washington ordered Washington\u2019s Department of Ecology to reconsider its denial of a petition for GHG rulemaking in light of the best available scientific evidence on climate change. The non-profit is also helping 19-year-old plaintiff Kelsey Juliana and another Oregon teen pursue a separate lawsuit<\/a> that evokes the state public trust doctrine in order to force further state action on climate change; the teens are in the process<\/a> of appealing a state judge\u2019s recent adverse decision to their suit. Notably, both of these cases involve state law, rather than federal law, and as such they will not affect the outcome of the latest lawsuit from Our Children\u2019s Trust.<\/p>\n

At the international scale, the June 2015 decision by the Hague District Court<\/a> in the Netherlands ruled for the Dutch government to further curb its GHG emissions beyond previously pledged targets, citing the European Convention on Human Rights, the Dutch Constitution, and principles of fairness, \u201cno harm,\u201d and hazardous negligence. (The Dutch government has not yet decided whether to appeal.) A similar suit has been filed in Belgium<\/a> and, according to NPR<\/a>, another is expected in Norway. Unlike in the U.S., the constitutions in the Netherlands, Norway, and Belgium include either a governmental mandate to protect the environment or an individual right to a clean environment. Thus, there is more reason to be optimistic about the outcomes of these cases.<\/p>\n

 <\/p>\n

\n

[1]<\/a> Complaint for Declaratory and Injunctive Relief at 85, Kelsey Cascadia Rose Juliana, Xiuhtezcatl Tonatiuh M. Et Al. v. United States, Barack Obama et al., No. 6:15-cv-01517-TC (D. Or. Aug. 12, 2015).<\/p>\n

[2]<\/a> Id. <\/em>at 91.<\/p>\n

[3]<\/a> Id.<\/em> at 90.<\/p>\n

[4]<\/a> Id.<\/em> at 92.<\/p>\n

[5]<\/a> Id. <\/em>at 93.<\/p>\n

[6]<\/a> Id.<\/em> at 7.<\/p>\n

[7]<\/a> Id.<\/em> at 6.<\/p>\n

[8]<\/a> Id.<\/em> at 13.<\/p>\n

[9]<\/a> Id.<\/em> at 16.<\/p>\n

[10]<\/a> Id.<\/em> at 49.<\/p>\n

[11]<\/a> Id.<\/em> at 50.<\/p>\n

[12]<\/a> See, e.g., <\/em>Summers v. Earth Island Institute, 555 U.S. 488 (2009); Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992); Amigos Bravos v. U.S. Bureau of Land Mgmt., 816 F. Supp. 2d 1118, 1133 (D.N.M. 2011); WildEarth Guardians v. Salazar, 880 F. Supp. 2d 77, 84 (D.D.C. 2012) aff’d sub nom,<\/em> WildEarth Guardians v. Jewell, 738 F.3d 298 (D.C. Cir. 2013). See also <\/em>Hope M. Babcock, The Problem with Particularized Injury: The Disjuncture Between Broad-Based Environmental Harm and Standing Jurisprudence, <\/em>25 J. Land Use & Envtl. L. 1-18 (2009).<\/p>\n

[13]<\/a> Lujan v. Defenders of Wildlife, 504 U.S. at 560, n. 1, 573-574.<\/p>\n

[14]<\/a> Id.<\/em> at 575 (citing United States v. Richardson, 418 U.S. 166, 171, 176\u2013177 (1974)).<\/p>\n

[15]<\/a> Massachusetts v. E.P.A., 549 U.S. 497, 499 (2007).<\/p>\n

[16]<\/a> Washington Environmental Council v. Bellon, 732 F.3d 1131, 1135 (9th Cir. 2013), reh\u2019g en banc denied<\/em>, 741 F.3d 1075 (9th Cir. 2014).<\/p>\n

[17]<\/a> Native Village of Kivalina v. ExxonMobil Corp., 663 F.Supp.2d 863, 881 (N.D. Cal. 2009), aff\u2019d on other grounds<\/em>, 696 F.3d 849 (9th Cir. 2012), cert. denied, <\/em>133 S. Ct. 2390 (2013). See also <\/em>Comer v. Murphy Oil USA, Inc., 839 F. Supp. 2d 849 (S.D. Miss. 2012) aff’d<\/em>, 718 F.3d 460 (5th Cir. 2013) (dismissed climate change claims by private plaintiffs, citing both the political question doctrine and lack of Art. III standing).<\/p>\n

[18]<\/a> Id.<\/em> at 876-77.<\/p>\n

[19]<\/a> Id.<\/em> at 877.<\/p>\n

[20]<\/a> American Electric Power v. Connecticut, 131 S. Ct. 2527, 2535, n. 6 (2011).<\/p>\n

[21]<\/a> In Baker v. Carr, <\/em>369 U.S. 186 (1962), the Supreme Court articulated six factors for determining whether a case presents a non-justiciable political question: (1) there is a \u201ctextually demonstrable constitutional commitment of the issue to a coordinate political department;” as an example of this, Brennan cited issues of foreign affairs and executive war powers; (2) a \u201clack of judicially discoverable and manageable standards for resolving\u201d the case; (3) the \u201cimpossibility of deciding without an initial policy determination of a kind clearly for nonjudicial discretion;” (4) the \u201cimpossibility of a court’s undertaking independent resolution without expressing lack of the respect due coordinate branches of government;” (5) an \u201cunusual need for unquestioning adherence to a political decision already made;” (6) the \u201cpotentiality of embarrassment from multifarious pronouncements by various departments on one question.”<\/p>\n

[22]<\/a> Connecticut v. Am. Elec. Power Co., 582 F.3d 309, 332 (2d Cir. 2009) rev’d<\/em>, 131 S. Ct. 2527, 180 L. Ed. 2d 435 (2011).<\/p>\n

[23]<\/a> American Electric Power v. Connecticut, 131 S. Ct. 2527 (2011).<\/p>\n

[24]<\/a> Native Village of Kivalina v. ExxonMobil Corp., 696 F.3d 849, 853 (9th Cir. 2012).<\/p>\n

[25]<\/a> PPL Montana, LLC v. Montana, 132 S.Ct. 1215, 1235 (2012).<\/p>\n

[26]<\/a> Alec L. v. Jackson, 863 F. Supp. 2d 11, 15 (D.D.C. 2012) aff’d sub nom. Alec L. ex rel. Loorz v. McCarthy, 561 F. App’x 7 (D.C. Cir. 2014) (noting that the \u201ccarefully considered language of the Supreme Court, even if technically dictum, generally must be treated as authoritative\u2026 [t]hus, dicta or not, the Court\u2019s statements regarding the public trust doctrine would nonetheless be binding on this Court\u201d).<\/p>\n

[27]<\/a> Alec L. ex rel. Loorz v. McCarthy, 561 F. App’x 7 (D.C. Cir. 2014).<\/p>\n

[28]<\/a> Washington v. Glucksberg, 521 U.S. 702, 706-07 (1997); Reno v. Flores, 507 U.S. 292, 302 (1993).<\/p>\n

[29]<\/a> Complaint at 86.<\/p>\n

[30]<\/a> See, e.g., <\/em>Pierce v. Society of Sisters, 268 U.S. 510 (1925) (the Compulsory Education Act of 1922 unreasonably interfered with the liberty of parents and guardians to direct the upbringing of and education of their children, because it mandated that all students attend public school; Loving v. Virginia, 388 U.S. 1 (1967) (laws prohibiting interracial marriage violated the right to choose one\u2019s spouse); O’Connor v. Donaldson, 422 U.S. 563 (1975) (state cannot constitutionally confine a non-dangerous mentally ill individual who is capable of surviving safely in freedom by himself).<\/p>\n

[31]<\/a> Envtl. Def. Fund, Inc. v. Corps of Engineers of U. S. Army, 325 F. Supp. 728, 739 (E.D. Ark.) supplemented, 325 F. Supp. 749 (E.D. Ark. 1971) (citations omitted).<\/p>\n

[32]<\/a> Ely v. Velde, 451 F.2d 1130, 1139 (4th<\/sup> Cir. 1971).<\/p>\n

[33]<\/a> In re Agent Orange Product Liability Litigation, 475 F.Supp. 928 (D.C.N.Y. 1979).<\/p>\n

[34]<\/a> Tanner v. Armco Steel, 340 F.Supp.532 (S.D. Tex. 1972).<\/p>\n","protected":false},"excerpt":{"rendered":"

By Nikita Perumal and Jessica Wentz A foundational component of sustainable development is the principle of inter-generational equity: that we should meet the needs of the present without compromising the ability of future generations to meet their own needs. 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