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Central Valley Chrysler-Jeep, Inc. v. Goldstene
United States District Court for the Eastern District of California
529 F. Supp. 2d 1151 (2007)
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.
Rule of Law
Holding and Reasoning (Ishii, J.)
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