Lincoln-Dodge, Inc. v. Sullivan

Two automobile manufacturers, two automobile manufacturers’ associations, and a group of Rhode Island automobile dealers (plaintiffs) collectively sued the Rhode Island Department of Environmental Management (RIDEM) (defendant), arguing that Rhode Island’s Regulation 37, which set automobile greenhouse-gas emissions standards, was preempted by the federal Clean Air Act (CAA) and the Energy Policy and Conservation Act (EPCA). Previously, the same manufacturers and associations had brought similar lawsuits in California and Vermont (the prior cases) challenging similar state emissions statutes. The California and Vermont rulings both held that neither the CAA nor EPCA preempted the respective state emissions statutes. The emissions statutes in California, Rhode Island, and Vermont were effectively identical. RIDEM argued that issue preclusion barred the manufacturers and associations from raising the preemption issue in the Rhode Island case because it had already been heard and decided in the prior cases. Although they were nonparties, RIDEM argued issue preclusion also applied to the Rhode Island dealers because they were virtually represented by the manufacturers and associations in the prior cases. The manufacturers, associations, and dealers countered, arguing issue preclusion did not apply because the prior cases and the Rhode Island case involved different defendants.