Held v. Montana

CDV-2020-307 (Aug. 14, 2023)

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Held v. Montana

Montana First Judicial District Court
CDV-2020-307 (Aug. 14, 2023)

Facts

Montana possessed significant energy resources, including fossil fuels such as coal and oil. Montana’s Department of Environmental Quality (DEQ) and Department of Natural Resources and Conservation (DNRC) were state agencies responsible for permitting and overseeing fossil-fuel-related activities in the state. The DEQ and the DNRC conducted environmental analyses under the Montana Environmental Policy Act (MEPA) to ensure that those activities complied with Montana’s environmental laws and regulations. In 2011, the Montana legislature amended MEPA to prohibit agencies that conducted environmental reviews from considering the regional, national, or global impacts of fossil-fuel-related activities. As a result of this MEPA limitation, the DEQ and the DNRC stopped analyzing the cumulative impacts of permitted projects on greenhouse-gas emissions or climate change. In 2019, fossil-fuel extraction, consumption, transportation, and processing in Montana alone resulted in greenhouse-gas emissions that exceeded many other countries’ total emissions levels. In 2020, Rikki Held and other Montana citizens between two and 18 years old (collectively, the youth) (plaintiffs) sued the State of Montana and various state officials and agencies, including the DEQ and the DNRC (collectively, the state) (defendants). The youth sought declaratory and injunctive relief, asserting that the MEPA limitation and Montana’s fossil-fuel-based energy system were unconstitutional. In 2023, while the action was pending, the Montana legislature further amended MEPA to explicitly prohibit agencies conducting environmental reviews from evaluating greenhouse-gas emissions and corresponding climate impacts in Montana or elsewhere. Montana also enacted SB 557, which eliminated certain preventative equitable remedies (i.e., vacatur and injunction) in MEPA challenges to agency decisions if the challengers raised issues regarding greenhouse-gas emissions or climate change. At trial on the youth’s MEPA-related claims, the court received evidence regarding, among other things, (1) the state’s knowledge of the dangerous climate impacts of extracting and burning fossil fuels and the projected increase in those impacts’ severity; (2) the negative economic and environmental consequences of anthropogenic (i.e., human-caused) climate change in Montana, including droughts, wildfires, heat stress, and harm to wildlife; (3) the unique detrimental impacts of climate change on children’s physical and mental health; and (4) the climate-change-related harms already being suffered by the youth. Following the trial, the court issued findings of fact and conclusions of law. After concluding that the youth had standing to assert their claims, the court considered the constitutionality of (1) the statutory amendments resulting from SB 557 and (2) the MEPA limitation.

Rule of Law

Issue

Holding and Reasoning (Seeley, J.)

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