Steel Co. v. Citizens for a Better Env't

523 U.S. 83, 118 S. Ct. 1003 (1998)

 

RULE:

The irreducible constitutional minimum of standing contains three requirements. First and foremost, there must be alleged (and ultimately proven) an injury in fact -- a harm suffered by plaintiff that is concrete and actual or imminent, not conjectural or hypothetical. Second, there must be causation -- a fairly traceable connection between plaintiff's injury and the complained-of conduct of defendant. And third, there must be redressability -- a likelihood that the requested relief will redress the alleged injury. This triad of injury in fact, causation, and redressability comprises the core of U.S. Const. art. III's case-or-controversy requirement, and the party invoking federal jurisdiction bears the burden of establishing its existence.

FACTS:

Respondent environmental protection organization filed a private enforcement action for declaratory and injunctive relief under Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) citizen-suit provision, 42 U.S.C.S. § 11046(a)(1) against petitioner manufacturer. Respondent alleged that petitioner had violated EPCRA by failing to file timely toxic and hazardous chemical storage and emission reports for past years. The district court held that because petitioner had brought its filings up to date by the time the complaint was filed, the court lacked jurisdiction to entertain a suit for a present violation; and that because EPCRA did not allow suit for a purely historical violation, respondent's allegation of untimely filing was not a claim upon which relief could be granted. The appellate court reversed and concluded that EPCRA authorized citizen suits for purely past violations. On further appeal, the Supreme Court of the United States vacated the judgment and remanded the case with instructions that the complaint be dismissed.

ISSUE:

Could respondent association bring a private enforcement action under the citizen-suit provision of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), 42 U.S.C.S. § 11000 et seq., for purely past violations?

ANSWER:

No.

CONCLUSION:

Respondent association failed to meet the redressability requirement of standing because none of the relief sought served to compensate the association for losses caused by petitioner manufacturer's late reporting or to eliminate any effects of that late reporting. The civil penalties authorized under 42 U.S.C.S. § 11045(c) were not payable to the association but rather to the United States Treasury, and psychic satisfaction with the results of a lawsuit was not an acceptable U.S. Const. art. III remedy because it did not redress a cognizable injury. Nor could respondent achieve standing by relying on 42 U.S.C.S. § 11046(f), which authorized reimbursement of the costs of bringing suit. Further, the injunctive relief sought to deter future violations was not redress for past infractions and was insufficient for purposes of Article III.

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