Steel Co. v. Citizens for a Better Environment
(1998)
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Rule of Law:
A plaintiff lacks Article III standing if the relief sought, such as civil penalties paid to the government treasury, does not directly remedy the plaintiff's particularized injury. The psychic satisfaction from seeing the law enforced or a wrongdoer punished is insufficient to establish the redressability requirement for constitutional standing.
Facts:
- The Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) requires companies using specified toxic and hazardous chemicals to file annual inventory and release forms by certain deadlines.
- From 1988 through 1995, Steel Company, a manufacturing company in Chicago, failed to file the required forms under EPCRA.
- In 1995, Citizens for a Better Environment (CBE), an environmental protection association, sent a notice to Steel Company, the EPA, and Illinois authorities, stating its intent to sue Steel Company for these past violations.
- Upon receiving CBE's notice, Steel Company filed all of its overdue forms with the relevant agencies.
- The Environmental Protection Agency (EPA) chose not to take any enforcement action against Steel Company.
Procedural Posture:
- Citizens for a Better Environment (CBE) filed a citizen suit against Steel Company in the U.S. District Court for the Northern District of Illinois.
- Steel Company filed a motion to dismiss, arguing that EPCRA does not authorize suits for purely historical violations and that the court lacked jurisdiction.
- The District Court granted the motion to dismiss.
- CBE, as appellant, appealed the dismissal to the U.S. Court of Appeals for the Seventh Circuit.
- The Seventh Circuit Court of Appeals reversed the District Court, holding that EPCRA does authorize citizen suits for past violations.
- The U.S. Supreme Court granted certiorari to review the Seventh Circuit's decision.
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Issue:
Does a plaintiff have Article III standing to sue a defendant for purely past violations of a federal statute when the only relief sought is civil penalties payable to the U.S. Treasury, injunctive relief for which there is no continuing or imminent threat, and litigation costs?
Opinions:
Majority - Justice Scalia
No. A plaintiff lacks Article III standing because the requested relief does not redress the alleged injuries. Federal courts must resolve questions of jurisdiction, including standing, before addressing the merits of a case. To establish standing, a plaintiff must demonstrate injury in fact, causation, and redressability. Assuming CBE suffered an injury from the lack of timely information, its claim fails the redressability prong. The civil penalties sought are payable to the U.S. Treasury, not CBE, and thus only provide a generalized 'psychic satisfaction' which is not a cognizable Article III remedy for a particularized injury. A request for litigation costs cannot independently create standing, and the requested injunctive relief is improper because CBE alleged only past violations, not a continuing or imminent future threat. Since none of the requested remedies would redress CBE's injury, it lacks standing, and the federal courts lack jurisdiction.
Concurring - Justice O'Connor
Joins the majority opinion. I agree that the respondent lacks Article III standing because its injuries are not redressable by a judgment requiring the payment of penalties to the U.S. Treasury. While federal courts must be certain of their jurisdiction before reaching the merits, the Court's opinion should not be read as an exhaustive list of all circumstances under which a court might reserve a difficult jurisdictional question while resolving the case on the merits in favor of the same party.
Concurring-in-part-and-dissenting-in-part - Justice Breyer
Agrees with the judgment and the majority's conclusion that the respondent lacks Article III standing. However, the Constitution does not impose a rigid judicial 'order of operations' requiring courts to always resolve jurisdictional questions before the merits. In some cases, practical concerns for judicial economy should allow a court to resolve an easier merits question first, particularly when the outcome for the parties would be the same, thus reserving difficult jurisdictional questions.
Concurring - Justice Stevens
Concurs in the judgment only. The Court should have first resolved the statutory question of whether EPCRA authorizes citizen suits for wholly past violations, which would have avoided creating new and unnecessary constitutional law on standing. Based on the precedent set in Gwaltney, the proper construction of EPCRA is that it does not authorize suits for violations that have been cured. Furthermore, the majority's redressability analysis represents a significant and questionable extension of prior case law, as punishment and deterrence have historically been considered forms of redress for an injury.
Analysis:
This case solidifies the 'jurisdiction first' principle, squarely rejecting the 'doctrine of hypothetical jurisdiction' that some federal circuits had adopted. It establishes that federal courts must confirm their Article III jurisdiction before ruling on the merits. The decision significantly narrows the redressability prong of the standing doctrine, making it more difficult for citizen-suit plaintiffs to sue for purely past statutory violations where the only remedies are civil penalties payable to the government and injunctive relief is moot. This holding impacts the enforcement of various environmental statutes that rely on citizen suits.
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