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Law School Case Brief

Engine Mfrs. Ass'n v. S. Coast Air Quality Mgmt. Dist - 541 U.S. 246, 124 S. Ct. 1756, 158 L. Ed. 2d 529, 2004 U.S. LEXIS 3232


Statutory construction must begin with the language employed by Congress and the assumption that the ordinary meaning of that language accurately expresses the legislative purpose. 

The South Coast Air Quality Management District is responsible under state law for developing and implementing a comprehensive basinwide air quality management plan to reduce emission levels and thereby achieve and maintain state and federal ambient air quality standards. Cal. Health & Safety Code Ann. § 40402(e) (1996).


Petitioners, an engine manufacturers association and an oil petroleum association, brought suit against respondents, California's South Coast Air Quality Management District and its officials (District), alleging that six local fleet rules promulgated by the District were pre-empted by § 209 of the Clean Air Act (CAA), 42 U.S.C.S. § 7543. Section 209(a) generally prohibits states from adopting or attempting to enforce "any standard" relating to the control of emissions. The federal district court, after concluding that the fleet rules were not "standard[s]" under § 209(a), granted summary judgment to the District, which was affirmed by the United States Court of Appeals for the Ninth Circuit. The Associations petitioned for certiorari review.


Does Section 209(a) of the Clean Air Act preempt the local fleet rules?




The United States Supreme Court vacated the judgments and remanded for further proceedings after determining that at least certain aspects of the Fleet Rules were preempted. The text of CAA § 209(a) and the CAA's structure did not support the district court's manufacturer-specific interpretation of "standard" or the resulting distinction between purchase and sale restrictions. The Court found that the command, accompanied by sanctions, that certain purchasers could buy only vehicles with particular emission characteristics was as much an "attempt to enforce" a "standard" as a command, accompanied by sanctions that a certain percentage of a manufacturer's sales volume had to consist of such vehicles.

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