Engine Manufacturers Association v. South Coast Air Quality Management District

541 U.S. 246 (2004)

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Engine Manufacturers Association v. South Coast Air Quality Management District

United States Supreme Court
541 U.S. 246 (2004)

  • Written by Tammy Boggs, JD

Facts

The South Coast Air Quality Management District (AQMD) (defendant) was a political subdivision of California responsible for controlling air pollution in Los Angeles County and surrounding counties. AQMD enacted six rules applicable to fleet operators (fleet rules) that prescribed the types of vehicles that operators were required to purchase or lease when adding or replacing fleet vehicles. For example, some of the rules required the purchase or lease of alternative-fuel vehicles, and some of the rules required the purchase or lease of vehicles that met certain emission specifications established by the California air-pollution-control regulatory body. The Engine Manufacturers Association (EMA) (plaintiff) sued AQMD, claiming that the fleet rules were preempted by § 209 of the Clean Air Act (CAA). The district court granted summary judgment to AQMD, entirely upholding the rules. The district court reasoned that the fleet rules were not emission “standards” because they regulated only the purchase of vehicles. The Ninth Circuit affirmed. The United States Supreme Court agreed to review the matter.

Rule of Law

Issue

Holding and Reasoning (Scalia, J.)

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