Steel Co. v. Citizens for a Better Environment
United States Supreme Court
523 U.S. 83 (1998)
The Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) created a system of state and local agencies tasked with ensuring that the public was informed about the presence of hazardous wastes. This system required hazardous-waste users to file forms reporting the details of their waste storage and releases each year. EPCRA authorized the use of citizen suits against waste operations that failed to file the required forms. After learning that Steel Company (Steel) (defendant) had not filed the required EPCRA reporting forms, Citizens for Better Environment (CBE) (plaintiff) sent notice of its intent to file a citizen suit. Steel promptly filed all of its overdue forms. CBE then filed suit in federal district court, seeking (1) a declaratory judgment that Steel had violated EPCRA, (2) permission to inspect Steel’s operations and records, (3) an order requiring Steel to provide CBE with copies of Steel’s EPCRA filings, (4) payment of civil penalties for each day of Steel’s violations, and (5) payment of CBE’s attorney fees and costs. Steel filed a motion to dismiss. The district court granted Steel’s motion, finding that there was no present violation of EPCRA. The United States Court of Appeals for the Seventh Circuit reversed, holding that EPCRA did authorize suits for purely past violations. The United States Supreme Court granted certiorari to determine whether CBE had standing to bring a citizen suit alleging past EPCRA violations.
Rule of Law
Holding and Reasoning (Scalia, J.)
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