Alec L. v. Jackson

The public-trust doctrine was established in Roman civil law and is grounded in English common law. Now, it has been applied to American common law to function as an obligation for governments to hold natural resources in trust for the benefit of the public. Public concerns over air pollution and the level of greenhouse gases, like carbon dioxide, in the atmosphere have grown. As part of the federal government’s response to air pollution and concerns over air quality, the United States Congress passed the Clean Air Act. The Clean Air Act mandated that the Environmental Protection Agency (EPA) and other federal agencies serve as the primary regulators of greenhouse-gas emissions and that the Clean Air Act displace any common-law rights to seek reductions in greenhouse-gas emissions. Alec L. and others (environmental group) (plaintiffs) sued Lisa Jackson (defendant) in her official capacity as administrator of the EPA and several other federal administrators (defendants) in federal district court. The complaint alleged that the federal administrators violated their fiduciary duty under the public-trust doctrine to preserve and protect the atmosphere from excessive carbon-dioxide emissions. The environmental group sought a declaration from the court that the EPA and other federal agencies have a duty to reduce atmospheric carbon-dioxide levels. The federal administrators filed a motion to dismiss the environmental group’s complaint for lack of federal jurisdiction and failure to state a claim.