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Constitutional Law Keyed to Chemerinsky

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Constitutional Law Keyed to Feldman Administrative Law Keyed to Funk Administrative Law Keyed to Aman Administrative Law Keyed to Asimow Administrative Law Keyed to Breyer Regulatory Law Keyed to Shapiro, 4th Ed.Legislative Process Keyed to Bressman, 4th Ed.

Massachusetts v. Environmental Protection Agency

Citation:

549 U.S 497 (2007)

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Facts

In the face of rising global temperatures, a group of states, local governments and private organizations alleged that the Environmental Protection Agency has not fulfilled its responsibility under the Clean Air Act to regulate the emissions of certain greenhouse gases. EPA argued that it need not address the questions of the petitioners unless they have standing to invoke the court’s jurisdiction under Article III of the Constitution.

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Q.1 - In articulating its finding that Massachusetts had standing to sue the EPA, the majority relied on which doctrinal innovation to distinguish the state’s interest from generalized grievances typically barred under Article III?

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(A) The fiction of constructive redressability, allowing judicially compelled reassessment to suffice where no regulatory outcome is guaranteed.

Incorrect. A is incorrect because redressability was not fictionalized but accepted on evidentiary grounds.

(B) The “special solicitude” doctrine, grounded in quasi-sovereign interests and traceable environmental harm.

Correct! The Court grounded Massachusetts’s standing in a “special solicitude” doctrine, recognizing that sovereign states asserting environmental harms over territorial erosion possess quasi-sovereign interests distinct from generalized grievances. This approach modified standard standing analysis by easing the traceability and redressability thresholds.

(C) The procedural injury exception, derived from Lujan v. Defenders of Wildlife, recognizing failure to follow statutory process as injury-in-fact.

Incorrect. C is incorrect as procedural injury was not central to the majority’s standing rationale.

(D) A presumption of justiciability in climate-related matters based on the precautionary principle in environmental governance.

Incorrect. D is incorrect because the precautionary principle is not part of U.S. justiciability doctrine.

Q.2 - In rejecting the EPA’s interpretation of its own discretion under the Clean Air Act, how did the majority structure its reasoning within the Chevron framework, and what interpretive posture did it adopt in doing so?

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(A) It concluded the statutory text was ambiguous but declined deference under Chevron Step Two due to the agency's failure to justify its policy judgment adequately.

Incorrect. A is incorrect because the Court found no ambiguity to reach Chevron Step Two.

(B) It bypassed Chevron entirely, applying the major questions doctrine to require clear congressional intent for climate-related regulatory expansion.

Incorrect. B is incorrect since the major questions doctrine was not invoked by the majority.

(C) It resolved ambiguity at Chevron Step One, holding that the statute unambiguously included greenhouse gases as pollutants, thus foreclosing deference.

Correct! The majority determined at Chevron Step One that the Clean Air Act’s definition of “air pollutant” clearly encompassed greenhouse gases, thus foreclosing deference and obliging the EPA to regulate. The Court employed a textualist approach grounded in the statute's plain language.

(D) It invoked Skidmore deference, granting only persuasive weight to EPA reasoning based on scientific uncertainty.

Incorrect. D is incorrect because Skidmore deference was neither applied nor appropriate where text was clear.

Q.3 - Which jurisprudential stance most accurately reflects the dissent's institutional critique of the majority’s intervention, and how did that stance affect the dissent’s approach to agency deference and judicial review?

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(A) Departmentalism, holding that each branch interprets the Constitution independently, thus obliging courts to defer only to statutory language, not agency interpretation.

Correct! The dissent implicitly adopted a departmentalist view, arguing that while courts must enforce statutory text, they should not override agency interpretations where no constitutional violation exists, thus drawing boundaries on judicial authority relative to administrative expertise.

(B) Functional separationism, asserting that institutional legitimacy requires judicial nonintervention where expert agencies are engaged in predictive policymaking.

Incorrect. B is incorrect because functional separationism would still allow judicial correction of misread statutes.

(C) Legal process theory, contending that judicial review must calibrate according to the procedural regularity of agency action rather than its substantive wisdom.

Incorrect. C is incorrect because the dissent did not focus on procedural review thresholds.

(D) Formalist textualism, emphasizing that interpretive legitimacy flows solely from statutory text, regardless of evolving regulatory context.

Incorrect. D is incorrect because although the dissent favored textualism, it emphasized institutional boundaries over interpretive purity.

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Massachusetts v. Environmental Protection Agency

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Massachusetts v. Environmental Protection Agency

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The Judicial Power Jurisdiction of Courts State Power (Federalism)

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Massachusetts v. Environmental Protection Agency