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City of New York v. Chevron Corp.

993 F.3d 81 (2021)

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City of New York v. Chevron Corp.

United States Court of Appeals for the Second Circuit
993 F.3d 81 (2021)

DD

Facts

The City of New York (city) (plaintiff) brought a state-law tort claim to hold a group of oil companies (the companies) (defendants) liable for the environmental damages that arose from the companies’ greenhouse-gas emissions. Because greenhouse gases mixed in the atmosphere, the emissions released by the companies had to be regulated far beyond the borders of the city. Hence, reducing the companies’ liability would have entailed restricting their conduct across every state. The district court dismissed the city’s complaint, finding that the city’s claim should have been brought under federal common law and that any such federal-law claim was preempted by the Clean Air Act (CAA). The city appealed.

Rule of Law

Issue

Holding and Reasoning (Sullivan, J.)

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