Central Valley Chrysler-Jeep, Inc. v. Goldstene

The Clean Air Act (CAA) required the United States Environmental Protection Agency (EPA) to maintain air quality by setting vehicle-emission standards for any pollutant that endangered public health or welfare. The CAA preempted state regulations regarding vehicle emissions, but § 209 of the CAA mandated that the EPA grant a waiver of preemption for state regulations that were, in the aggregate, at least as stringent as EPA standards (and if certain other criteria were met). Once a state regulation was granted a waiver, other states that adopted the same regulation would be deemed in compliance with the CAA. A separate federal law, the Energy Policy and Conservation Act (EPCA), required the Department of Transportation, through the National Highway Traffic Safety Administration, to set federal fuel-economy standards for new vehicles. The EPCA contained a provision requiring the National Highway Traffic Safety Administration to consider other federal motor-vehicle standards in developing regulations. Unlike the CAA, the EPCA did not permit a waiver of preemption for state fuel-economy regulations. California enacted aggressive vehicle-emission standards, for which the EPA granted a waiver of preemption under § 209 of the CAA. Central Valley Chrysler-Jeep, Inc. (plaintiff) challenged the state regulations in federal district court and asked the court to find that a state law that was granted a waiver of preemption under the CAA was nevertheless preempted by the EPCA if the state law had a more than de minimis effect on fuel efficiency. The California agency that adopted the regulations (defendant) argued that a state regulation that was granted a waiver of preemption under the CAA was not subject to preemption under the EPCA.