Contents


    Executive Summary

    Climate change is arguably the most pressing global challenge of our time, and the devastating impact it has on our environment, economies, and societies is already being felt around the world. While international cooperation and national policies are essential to tackling climate change, litigation has also emerged as an increasingly important tool to hold governments and corporations accountable for their actions and inactions on this issue. The litigation falls into two schools. The first is made up of public law actions against governments and public officials, and the second is constituted by private law actions. The total number of climate change-related litigation cases has more than doubled worldwide since 2015. As of March 2023, the Sabin Center for Climate Change Law database contains more than 2,700 climate change-related lawsuits spanning 49 different countries. Nearly 2,000 of these cases have been filed in the United States alone. Climate litigation cases have also been filed before 15 international or regional courts and tribunals, including the Courts of the European Union and various United Nations (UN) bodies. Most litigation in the United States is related to duty of care or failure to warn, either by corporations or government entities. Experts have compared the extent of the litigation to cases against tobacco and asbestos, underlining the serious nature of the claims.

    To learn more about climate change, please refer to the Climate Change Insurance Risk Database.

    Background

    The roots of climate change litigation can be traced back to the 1980s and 90s, when scientists first began to warn about the potential consequences of greenhouse gas emissions and the need to curb their production. The current proliferation of climate cases is occurring within the context of an increase in public awareness and an ever-strengthening scientific consensus related to anthropogenic climate change. Furthermore, international commitments coupled with governmental responses to climate change have resulted in a large volume of new laws and regulations, such as taxes on carbon and restrictions on certain materials or processes, in many nations around the world. These regulations lead to a greater compliance burden on companies, especially in high emitting sectors. The enforcement of these laws and regulations can give rise to regulatory investigation, sanctions, fines or litigation. These factors have contributed to an atmosphere where governments and companies are increasingly finding themselves on the receiving end of lawsuits that challenge their actions or inactions on climate change.

    Many of these suits allege violations of state tort law for negligence and public nuisance. Some federal judges have dismissed these lawsuits, arguing that the courts are not the proper forum to settle climate change-related issues. They contend that these suits involve regulatory disputes that should be taken up by the legislative and executive branches. A spokesperson for Royal Dutch Shell expressed a similar sentiment, stating, “We believe climate change is a complex societal challenge that should be addressed through sound government policy and cultural change ... not by the courts.” Some judges have agreed, holding that climate change is too vast an issue to hold just five major oil companies liable.

    This wave of lawsuits comes on the heels of reports that some fossil fuel production companies promoted public relations schemes, intending to misinform the public on the threat of climate change and its direct relationship to the oil industry. The reports allege that these companies discouraged the development of alternate energy as well as advertised in favor of the notion that more carbon dioxide in the atmosphere could foster plant growth and global crop yields. ExxonMobil is at the center of most climate change litigation. Facing lawsuits from external parties, localities, and its own shareholders, Exxon has also been accused of heavily funding climate change denial groups.

    This increase in climate change litigation has initiated a series of jurisdictional battles and choice of law questions. Plaintiffs, most of whom are states and localities, believe that their claims have a better chance of success in state courts, whereas defendants prefer to litigate in federal courts. Defendant companies are desperate to avoid discovery and believe that they have a better chance of dismissal in federal court. As such, many of these suits are currently stranded on jurisdictional appeal.

    Climate change litigation suits also raise choice of law issues. Does federal law or state law govern climate change? Plaintiffs have argued that state policy governs the issue, whereas defendants argue that compliance with federal regulations is enough. Admittedly, these questions lack clear answers and are being left up to the discretion and interpretation of state and federal judges.

    Injuries and Damages

    Climate change has been linked to more frequent and intense natural disasters. These have led to an increase in damage done to individuals and communities. Events such as flooding, fires, and drought have the potential to cause injury and risk.

    Many of the cases filed in relation to climate change are due to a damage or injury incurred from a changing climate. This includes damage sustained after a natural disaster event to the plaintiff. In these suits, they claim the injuries could have been avoided had the defendant completed whatever task was required to curb the effects of climate change.

    Climate change can bring about more than physical damage, such as to a home or business. It can also cause serious health risks for the more vulnerable population. This includes children, the elderly, and the poor. Experts have noted that climate change and the ensuing disaster also have the potential to disproportionately affect underprivileged communities, or communities of color, due to existing systemic inequalities. In the face of increased natural disasters as the result of climate change, wealthier populations are more able to safely evacuate, whereas others may find themselves at higher risk for injuries and damages. A drought or heat wave puts those at risk in a precarious position.

    Despite the serious and extensive risks associated with climate change, climate-related cases have proven to be difficult to win as attributing specific loss and damage to a particular company’s behavior or emissions profile is exceedingly challenging. However, as the field of ‘attribution science’ continues to evolve, the legal evidential basis for plaintiffs to rely on is becoming more robust. If such cases are successful, the deep pockets of companies will be established as a viable source for vulnerable communities to access compensation for injuries and damages. It could also lead to a more general discussion of how companies could contribute to loss and damage funding on an international scale.

    Legislation and Regulation

    Clean Air Act
    The Clean Air Act (CAA) is a comprehensive federal law that established national standards for emissions and hazardous pollutants through the National Ambient Air Quality Standards (NAAQS). Administered by the Environmental Protection Agency (EPA), the CAA was passed in 1963 and subsequently amended in 1977 and 1990. It is one of the United States’ first and most influential modern environmental laws. Furthermore, it is one of the most common laws being implicated in climate change litigation. This federal law has been cited in the dismissal of climate change suits against big oil companies, where violation of state law is being alleged but the companies are in compliance with the Clean Air Act.

    The Clean Air Act enables the federal government to conduct investigations into the enforcement of interstate air pollution limits for the promotion of public health. It also allows the EPA to perform ambient monitoring studies and stationary source inspections. Additionally, the CAA gives the EPA the authority to place air quality and emissions limitations on airplanes and motor vehicles, as well as regulate noise pollution and acid deposition control. With each new administration, the EPA issues new policies that can either tighten or relax these standards for emissions. Roughly 200 cases of climate change litigation have been filed under the CAA.

    Clean Water Act
    The 1972 Clean Water Act (CWA) establishes regulations for discharging pollutants in the United States waters and maintaining quality standards. The CWA allows the EPA to implement programs that aim to control water pollution levels. These programs include a wastewater standard by industry and national water quality criteria to ensure that surface water is kept at a pollutant safe level. Most notably, the law prohibits the discharge of any pollutant into navigable waters without a permit. 63 cases of climate change litigation have been filed under the CWA.

    Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
    This 1980 law was designed to tax chemical and petroleum industries and designate federal authority over the release of hazardous substances. In regard to waste dumping sites, the act established prohibitions and requirements regarding abandoned sites, and allowed the person responsible for the release of the material to be held liable. The act lays out a variety of actions that can be taken, either short-term removals or long-term remedial actions, in response to the release of hazardous waste that may put the population at risk.

    Endangered Species Act
    The Endangered Species Act (ESA) of 1973 provides a framework for the conservation and protection of endangered or threatened plants and animals and their habitats. Federal agencies are required to ensure that actions they authorize, fund, or carry out are not likely to threaten the continued existence of any listed species or result in the destruction or adverse modification of the habitat of such species. The ESA is commonly implicated in climate change litigation, with nearly 200 cases filed under this law.

    Inflation Reduction Act
    In August 2022, President Biden signed the Inflation Reduction Act (IRA) into law, marking the most significant step Congress has taken to address the climate crisis. In addition to its aim to curb inflation and lower drug prices, the bill invests $369 billion in climate solutions and environmental justice. The bill also outlines a path toward achieving a 40% emissions reduction by 2030. Clean energy tax credits and other provisions included in the bill are intended to encourage the production of clean energy domestically and accelerate energy innovation abroad. Additionally, the IRA is helping to promote a fair and equitable transition to clean energy by investing in disadvantaged communities and prioritizing projects that reutilize retired fossil fuel infrastructure and employ displaced workers, and by including incentives for adopting energy efficient agriculture practices.

    National Environmental Policy Act
    The National Environmental Policy Act (NEPA), signed into law in 1970, is widely considered to be the foundational environmental law in the U.S. NEPA requires all branches of government to consider climate change and other environmental harms when analyzing the effects of proposed actions including: development of major pipelines, bridges, highways, parkland purchases, and other projects. NEPA also established the President’s Council on Environmental Quality (CEQ), the federal body charged with implementing NEPA. In 2021, CEQ announced a plan to embark on a review of NEPA’s implementing regulations in an effort to ensure that they are commensurate with current environmental, climate change, and environmental justice objectives.
    NEPA is the most common law implicated in climate change litigation. To date, 346 U.S. climate change cases have been filed under this statue.

    Resource Conservation and Recovery Act
    The Resource Conservation and Recovery Act (RCRA) most notably gives the EPA authority over hazardous and non-hazardous waste. The life of hazardous waste can include generation, transportation, treatment, storage, and disposal, meaning that the EPA has control over every aspect of this process, taking care to ensure that the waste is not incorrectly managed. A 1984 group of amendments, the Federal Hazardous and Solid Waste amendments, focus further on conservation efforts such as minimizing the waste in the first place.

    Liability and Insurance

    D&O Coverage
    In March 2022, the U.S. Securities and Exchange Commission (SEC) proposed mandatory reporting of publicly traded companies’ climate risks, including the level of greenhouse gas emissions companies produce, both directly and indirectly, how climate risk affects their business, and their plans to meet climate-related goals. The proposed rule, expected to be finalized in April 2023, increases the likelihood that directors and officers could face lawsuits that allege they directly contributed to climate change. Allegations against directors and officers might include liability disclosure, financial impact disclosure, business strategy disclosure, compliance failure, ancillary violations, and investment liability. The extensive degree to which D&O coverage might be implicated in climate change litigation has prompted some insurers to voice their intention to rely on policy exclusions, such as the standard ‘pollution exclusion’, to restrict coverage and mitigate risk.
    Directors & officers liability coverage has been implicated in landmark suits. For example, during the 2015 Volkswagen emissions scandal, former CEO of Volkswagen, Martin Winterkorn, was sued for defrauding investors and lying to cheat U.S. emissions standards. More recently, in August 2018, shareholders sued ExxonMobil executive officers for misleading the public and its investors, in addition to submitting false accounting reports to the U.S. Securities and Exchange Commission.
    Product Liability Risks
    Product liability risks are likely to be implicated in climate change litigation. One argument to be made is for product liability in tort claims. Here, lawsuits may be brought on the basis that allegedly defective products caused environmental harm that resulted in property damage or financial loss. Moreover, lawsuits for tort claims in product liability are more likely to be brought in state courts under state law, rather than in federal courts under federal law. In fact, some of the lawsuits brought against major oil companies allege that petroleum is a defective and environmentally harmful product for which defendant companies are strictly liable. Additionally, lawsuits could also stem from efforts to switch to greener products that utilize relatively new technologies. For example, lithium-ion batteries used in electric vehicles pose a heightened fire risk.
    General Liability Coverage
    General liability insurance typically covers claims made for third party property and bodily damage. For climate change litigation, coastline states are alleging property and infrastructural damages suffered as a result of global warming and rising sea levels. If these claims succeed in court, companies will be required to invoke general liability coverage to pay the damages.

    Litigation

    Held v. State of Montana
    On March 13, 2020, 16 young people filed a lawsuit asserting climate change-based claims under the Montana constitution against the State of Montana, Montana’s governor, and various state agencies. The plaintiffs claim that Montana is violating their constitutional rights to a “clean and healthful environment; to seek safety, health, and happiness; and to individual dignity and equal protection of the law.” The case specifically questions the constitutionality of Montana’s fossil fuel-based State Energy Policy and the “Climate Change Exception” in the Montana Environmental Policy Act.

    In a historic judgement on August 4, 2021, Judge Kathy Seeley ruled that the case could proceed to trial. Schedule to begin on June 12, 2023, this will be the first ever youth-led climate trial in U.S. history.

    Connecticut v. ExxonMobil Corp.
    On September 14, 2020, Connecticut Attorney General William Tong brought a lawsuit against ExxonMobil claiming the company had misled consumers and investors about the risks of climate change and their role in contributing to it. The suit alleges that ExxonMobil has violated the Connecticut Unfair Trade Practices Act by engaging in unfair and deceptive practices related to climate change, specifically, that the company knowingly misled consumers and investors by downplaying the risks of climate change and failing to disclose its own internal knowledge about the dangers of greenhouse gas emissions. Connecticut’s complaint lists a “myriad [of] negative consequences” to which Exxon has allegedly contributed including sea level rise, flooding, drought, increases in extreme temperatures and severe storms, and decreases in air quality, among others.

    Connecticut’s lawsuit includes eight counts under the Connecticut Unfair Trade Practices Act and is seeking “injunctive and equitable relief; civil penalties; restitution for State expenditures attributable to Exxon to respond to the effects of climate change; disgorgement of revenues, profits, and gains; disclosure of research and studies on climate change; and funding of a corrective education campaign.”

    The lawsuit draws substantially on the defendants’ own internal memos which the state alleges clearly demonstrate the companies’ awareness of the connection between fossil fuel consumption and climate change, and the impacts of climate change to our environment, economy, and public health. The lawsuit then contrasts these internal memos with public messages from the companies which the state claims to be “deceptive” and “misleading”.

    This case has proceeded in a manner similar to many other climate litigation cases where a battle over jurisdiction has been the principal issue. Following Connecticut Federal Court’s 2021 ruling to remand the lawsuit to state court, the defendants filed an appeal with the Second Circuit Court of Appeals. Connecticut has since filed several supplemental authority letters citing decisions by the First, Third, Fourth, Ninth, and Tenth Circuit Courts all of which ruled to remand similar climate change cases to state court. The Second Circuit Court is yet to rule on this case.

    City & County of Honolulu v. Sunoco LP
    In March 2020, the City and County of Honolulu filed a suit alleging that the actions of fossil fuel companies directly and proximately caused “a substantial portion of the climate crisis-related impacts in the City” including sea level rise, extreme weather, ocean warming and acidification, and “the cascading social, economic, and other consequences of those environmental changes.” The alleged wrongful conduct also included “concealing the dangers of, promoting false and misleading information about, and engaging in massive campaigns to promote increasing use of their fossil fuel products.” Honolulu asserted claims of public nuisance, private nuisance, strict liability for failure to warn, and trespass. The City is seeking compensatory damages and other forms of relief.

    After being subject to the typical battle over jurisdiction, this case is currently awaiting a ruling from the Supreme Court on the question of “whether a federal district court has jurisdiction under 28 U.S.C. § 1331 over nominally state-laws seeking redress for injuries allegedly caused by the effect of transboundary greenhouse-gas emissions on the global climate, on the ground that federal law necessarily and exclusively governs such claims.” The question is essentially the same as the question presented in several other climate cases for which certiorari petitions are currently pending.

    The appeal filed before the Supreme Court could have a significant impact on the proceedings in Hawaii. The oil companies are hoping to upend a series of circuit court decisions remanding the cases to state courts where they were filed. If the high court takes the appeal and rules for the oil companies, the precedent would be established for climate change cases to be litigated in federal court. The Supreme Court is expected to rule on this case later this year.

    California v. Trump
    As of 2021, the state of California had filed 110 lawsuits against the Trump administration over its environmental laws, immigration policies and other regulations and rollbacks. The attorney general’s office has won 23 cases and lost 5 while the remaining 82 are pending or on hold.

    The content of the various lawsuits addresses policies from the EPA and Department of the Interior, and each complaint was filed in federal court. California is also one of eleven states vowing to uphold the policies set forth in the Paris Climate Agreement, which President Trump formally withdrew from in June 2017.

    In April 2019, California joined Oregon and Minnesota in a lawsuit challenging President Trump’s Executive Order 13771 on “Reducing Regulation and Controlling Regulatory Costs.” The states allege that Trump’s executive order has caused a failure to finalize regulations proposed during the Obama Administration. These regulations intended to address energy conservation and curb greenhouse gas emissions.

    The states’ complaint also included allegations of climate change-related impacts and lack of nationwide solutions to greenhouse gas emissions. The lawsuit rests on the claims for violations of the separation of powers doctrine, the Take Care Clause, and the Administrative Procedure Act. The basis of these claims is an assertion that the president breached his duty of exercising due care while executing laws and that administrative agencies acted outside the scope of their authority. The states make the case that the order delayed the implementation of important standards and regulations, resulting in further climate change injuries.

    In 2020, the States’ challenge to the executive order was dismissed by the federal district court for the District of Columbia, concluding that the evidence did not prove that the executive order caused the delay in regulatory actions contributing to injuries from climate change. Despite the ruling and subsequent dismissal of the case, the court did assert that the delay in standard finalization did contribute to climate change and injuries the states had suffered on the basis of climate change.

    County of San Mateo v. Chevron Corp.
    Beginning in July 2017, six California municipalities filed separate lawsuits in state court against several major oil companies including Chevron, BP, Royal Dutch Shell, Exxon Mobil, and ConocoPhillips. The suits allege damages based on claims for public nuisance and seek to hold the oil industry accountable for climate impacts affecting the State of California, including extreme heat and sea level rise. The lawsuits also allege that the companies concealed the climate hazards associated with the production and use of their products.

    Defendant companies removed the case to federal district court on the claim that they are entitled to removal under the “federal officer removal” statute. Federal officer removal is a doctrine for removing certain cases from state to federal court and is available to federal officers or persons acting under them. This includes corporations. The defendants allege that certain contracts they have with the federal government required them to take some of the actions for which they are now being sued. The district court held that the defendant companies alleged improper grounds for federal removal jurisdiction and remanded the case back to state court. Defendant companies reasserted federal officer removal and appealed to the U.S. Court of Appeals for the Ninth Circuit.

    The Ninth Circuit granted a request to put all current cases against the fossil fuel companies in front of one judicial panel in December 2019. In May of 2020, the Ninth Circuit court presented the opinion that rejected the oil companies' argument that they were acting under a federal officer, dismissing the appeal of the defendant companies. This decision impacts the precedent for “federal officer removal” statute, underscoring the ability of climate change cases to be heard in state courts.

    At the end of 2020, the fossil fuel companies were granted a motion to stay the mandate in order to file a petition for writ of ¬certiorari in the Supreme Court. In 2021, the defendants were granted another chance to argue for removal to federal court based on the Supreme Court ruling in a similar case filed by the city of Baltimore.

    In April of 2022, the Ninth Circuit court affirmed, for a second time, a district order remanding to state court climate lawsuits brought by California local governments against fossil fuel companies. In the 2020 ruling where the Ninth Circuit initially affirmed the remand order, it only reviewed the legitimacy of removal under the federal-officer removal statute. In this second decision, the Ninth Circuit reviewed the defendant companies’ other arguments and rejected “broad interpretations of removal jurisdiction” even in a case where the plaintiffs “raise novel and sweeping causes of action.”

    Currently, this case is waiting on a ruling from the Supreme Court similar to Honolulu v. Sunoco LP. The fossil fuel companies once again petitioned the Ninth Circuit court for a stay of mandate and filed a writ of certiorari seeking the Supreme Court’s review of the Ninth Circuit’s decision. The stay of mandate was granted, and the Supreme Court is yet to provide a ruling on this case.

    City of Oakland v. BP
    In September 2017, attorneys for the cities of Oakland and San Francisco filed separate public nuisance lawsuits, on behalf of the People of the State of California, against five of the world’s largest producers of fossil fuels. The defendant companies are British Petroleum, Chevron, ConocoPhillips, Exxon Mobil, and Royal Dutch Shell.

    The suits asked that the courts hold the companies responsible for the costs of sea walls and other infrastructure necessary to protect California’s citizens from the ongoing consequences of climate change and sea level rise that will directly impact Californian coastal communities. The lawsuits state that these costs are the direct consequences of: the defendants’ wrongful promotion of their products, deliberate concealment of their knowledge of the direct link between fossil fuels and climate change, and campaigns to discredit evidence supporting said link.

    The defendant companies had the case removed from state to federal district court, where a federal judge granted defendants’ motion to dismiss for failure to state a claim and lack of personal jurisdiction. San Francisco and Oakland appealed that ruling to the Ninth Circuit, where the two cities have maintained that their claims are covered under California’s public nuisance laws and should remain in state court.

    In May 2020, the Ninth Circuit vacated and remanded. Judge Ikuta held that the Cities’ claims failed to implicate federal law based on various jurisdictional criteria that were not met. As a result, the court remanded the cases to the district court to determine if there were any other grounds for removal to federal court. The fossil fuel companies filed a writ of certiorari seeking the review of the Ninth Circuit’s decision which was ultimately denied by the Supreme Court in June of 2021.

    In October of 2022, the federal district court for the Northern District of California rejected the defendants’ remaining grounds for removal to federal court and concluded that Ninth Circuit precedent dictates the remand of Oakland and San Francisco climate cases to state court.

    City of New York v. BP
    In January 2018, attorneys for the City of New York filed a complaint in federal court against five major petroleum companies. The complaint made claims for public and private nuisance and for trespass. The city is requesting unspecified damages and injunctive relief. In addition, the city is seeking damages from the oil companies to pay for infrastructure improvements needed to protect the city’s 8.5 million residents from climate change impacts.

    U.S. District Judge John Keenan dismissed the complaint in July of 2018. Judge Keenan said that the federal Clean Air Act takes legal precedence over emissions and trumps New York State law. He also ruled that the executive and legislative branches, not the courts, are the proper forum to address climate change impacts. The City of New York immediately filed an appeal with the Second Circuit Court of Appeals to reverse the dismissal. In April 2021, the Second Circuit upheld the dismissal, concurring that federal common law displaced the City’s state-law public nuisance, private nuisance and trespass claims based in part on the view that state law claims “would further risk upsetting the careful balance that has been struck between the prevention of global warming, a project that requires national standards and global participation, on the one hand, and energy production, economic growth, foreign policy, and national security on the other.”

    Board of County Commissioners of Boulder County v. Suncor Energy (U.S.A.)
    On April 17, 2018, Colorado communities of Boulder County, San Miguel, and the City of Boulder filed a lawsuit against Suncor and ExxonMobil, alleging common-law public nuisance claims, as well as violations of the Colorado Consumer Protection Act. The lawsuit alleges that the two oil companies are the most significant contributors to climate change and demands that they pay for costs associated with climate change impacts so that these costs do not “fall disproportionately on taxpayers.” The suit states that Colorado is one of the fastest warming states in the U.S. and is already experiencing trends in rising heat index, drought, and more frequent wildfires.

    The complaint asserts that defendant companies have known about the risk of climate change impacts for over fifty years and failed to inform the public of that risk. It is deducted that the localities included Suncor in their claim against Exxon because Suncor U.S.A.’s corporate headquarters are in Colorado. Plaintiffs intended to eliminate federal diversity jurisdiction and limit the defendant companies’ ability to argue that the suit should be heard in federal rather than state court. Despite this attempt, a jurisdictional battle was waged.

    The fight over jurisdiction began when, three weeks after the plaintiffs amended their complaint to include civil conspiracy claims, the defendants filed for removal to federal court. Defendant companies asserted that the claims could only arise under federal common law due to the “uniquely federal interests” at stake, including energy, environmental, and national security policy. Additional grounds for removal include the preemption of Colorado law by the federal Clean Air Act. In retaliation, the plaintiffs filed a motion to remand the action back to state court, arguing that their claims arose under only Colorado state law. On September 5, 2019, the motion to remand was granted by a federal judge for the U.S. District Court for the District of Colorado.

    At the end of 2021, the Supreme Court granted Suncor’s writ for certiorari to the United States Court of Appeals for the Tenth Circuit for further consideration in light of BP v. Mayor and City Council of Baltimore. The appeals court ultimately affirmed the district court's ruling and dismissed the appeal. On March 2, 2022, the Tenth Circuit Appeals Court issued a mandate transferring jurisdiction back to the lower court.

    In June 2022, the fossil fuel companies filed yet another petition for writ of certiorari seeking the Supreme Court’s review of the Tenth Circuit’s decision affirming the remand to state court. Following the writ of certiorari, several amicus curiae briefs were filed in support of petitioners by various states, trade associations, and others. Most recently, the Supreme Court has invited the Solicitor General to file a brief expressing the views of the United States on the petition for writ of certiorari filed by fossil fuel companies.

    King County v. BP
    On May 9, 2018, King County, Washington filed a lawsuit against the five largest oil companies: BP, Chevron, ExxonMobil, Royal Dutch Shell, and ConocoPhillips. The lawsuit seeks to hold the companies responsible for making major contributions to overall climate disruptions. The complaint seeks an order requiring the companies to pay into an abatement fund for the costs of adapting infrastructure to address climate change risks. These include costs for stormwater management, salmon recovery, floods, landslides, and ocean acidification. The complaint asserts that the companies have directly contributed to rising sea levels which have caused regular flooding in areas once above the high tide line.

    Lawyers brought the suit in King County Superior Court. A federal judge granted defendant companies’ motion for removal to federal court and rejected King County’s motion to move the case back to state court. The same attorneys that represent King County are representing San Francisco and Oakland County in a separate, but materially identical lawsuit. A U.S. District Judge granted motion to stay proceedings brought by the county, pending a ruling from the Ninth Circuit Court of Appeals on City of Oakland v. BP.

    Following the Supreme Court's denial of the petition for writ of certiorari in the City of Oakland v. BP, the parties informed the court they had been discussing next steps and requested a continuation of the stay. Proceedings remained stayed until July 2021 when the court granted the parties’ stipulated motion regarding deadlines for when the defendants would have to file a motion to dismiss. Ultimately, on September 28, 2021, King County filed a notice of voluntary dismissal of its climate change lawsuit against the defendants.

    Rhode Island v. Shell Oil Products Co.
    On July 2, 2018, Rhode Island became the first state to bring suit against the oil industry. When announcing the lawsuit, then Rhode Island Attorney General Peter Kilmartin said, “For a very long time, there has been this perception that ‘Big Oil’ was too big to take on, but here we are- the smallest state- taking on some of the biggest corporate polluters in the world.” The lawsuit was filed in Providence County Superior Court and named Exxon, BP, Royal Dutch Shell, ConocoPhillips, and Chevron as defendants.

    In the initial complaint, defendant companies are accused of contributing to climate change that is damaging infrastructure and coastal communities in the state. The public nuisance suit is seeking to force the defendant companies to pay unspecified compensatory and punitive damages associated with climate change. As a state with over 400 miles of open coastline, it also alleges that the companies violated Rhode Island’s Environmental Rights Act by polluting and destroying its resources.

    Another jurisdictional battle took place when defendant companies removed the case to federal court. Following removal, Rhode Island filed a motion to remand to state court. Defendants argued that federal jurisdiction existed over climate litigation cases, as evidenced by the stream of previous climate cases that failed in federal court under the Clean Air Act. But Rhode Island argued that the nature of their complaint is about tortious misrepresentation and failure to warn- claims that tend to be governed by state law. On July 22, 2019, the state’s motion to remand was granted, but the federal district court stayed the remand order for 60 days. The court denied motion to stay remand order pending an appeal and directed that the remand order not be entered until October 10, 2019.

    In 2022, the First Circuit Court of Appeals remanded the case to state court, after rejecting the fossil fuel companies’ arguments that the claims were governed by federal law. The First Circuit had already remanded the case in 2020, but the Supreme Court ordered it to review the previous ruling after the high court gave the companies another opportunity to argue for removal in a similar case by the city of Baltimore. Following the 2022 remand order, defendant companies filed another writ for certiorari seeking the Supreme Court’s review of the First Court’s affirmation of the remand of Rhode Island’s case to state court. As of January 2023, two amicus briefs were filed in support of fossil fuel companies’ petition for writ of certiorari. The Supreme Court is yet to rule on this case.

    Mayor & City Council of Baltimore v. BP
    In July 2018, the city of Baltimore joined other localities in filing a string of lawsuits against the fossil fuel industry. The complaint filed named 26 oil and gas companies and is seeking unspecified damages, penalties, and relief under Maryland state trespass law and the Maryland Consumer Protection Act. It says that the city of Baltimore has been adversely impacted by the sea level rise attributed to climate change. It argues that these impacts have caused “property damage, economic injuries, and impacts to public health.” The complaint alleges that the industry identified a link between climate change and fossil fuel production. It also alleges that fossil fuel producers then spent the better half of 50 years working to hide the dangers of climate change to protect the industry rather than mitigate the damages.

    A Shell spokesman responded to the lawsuit with the statement that, “We believe climate change is a complex societal challenge that should be addressed through sound government policy and cultural change…not by the courts.” A jurisdictional battle was waged when defendant companies removed the case to federal court.

    After several years spent arguing over the procedural issue of removal, in 2022 the Fourth Circuit Court of Appeals held, for the second time, that the City of Baltimore’s lawsuit should proceed in state court. The Supreme Court vacated the Fourth Circuit’s initial remand decision based on the high court’s assertion that federal appellate courts are required to consider all grounds for removal when federal-officer removal is one of the asserted grounds. Following this ruling, the Fourth Circuit maintained its rejection of federal-officer removal as a basis for subject matter jurisdiction in this case and rejected the seven other grounds on which defendant companies were seeking removal.

    The fossil fuel companies filed another petition for writ of certiorari in October 2022. The petition presents two questions: “(1) Whether federal common law necessarily and exclusively governs claims seeking to redress for injuries allegedly caused by the effect of interstate greenhouse-gas emissions on the global climate; and (2) Whether a federal district court has jurisdiction under 28 U.S.C. 1331 over claims necessarily and exclusively governed by federal common law but labeled as arising under state law.” These questions are the same as the ones presented in the pending petition for writ of certiorari seeking review of the Tenth Circuit’s affirmation of the remand order in Colorado local governments’ climate case.

    People of the State of New York v. ExxonMobil
    In October 2018, Attorney General Barbara Underwood filed a fraud lawsuit against ExxonMobil in New York state court. It accused the company of misleading Exxon investors on how future regulations could impact its business. The lawsuit comes on the heels of a three-year investigation into the company’s public disclosures. Investigations revealed that Exxon executives kept two sets of books that accounted for potential costs of greenhouse gas regulations; one set was made public while the other was used for internal calculations.

    The investigation “uncovered significant evidence of potentially materially false misleading statements by Exxon about its application of a proxy cost of greenhouse gas emissions to its investment and impairment decisions.” The company was facing both civil and criminal penalties under the Martin Act: one of New York’s toughest anti-fraud statutes. Exxon was also facing a similar probe by Massachusetts Attorney General Maura Healey. Exxon sued Maura Healey in both state and federal courts, with courts upholding the AG’s authority to investigate.

    The trial began on October 22, 2019. At the time, it was only the second climate change lawsuit to reach trial in the U.S. After a twelve-day trial, the court ultimately ruled in favor of Exxon. The New York court found that the New York Office of the Attorney General “failed to establish by a preponderance of the evidence” that ExxonMobil made any material misstatements or omissions that misled any reasonable investor about its practices or procedures for accounting for climate risk.

    In his decision, Judge Barry Ostrager took care to emphasize that this verdict did not deal with the issue of Exxon’s possible contribution to climate change. “Nothing in this opinion is intended to absolve Exxon Mobil from responsibility for contributing to climate change in the production of its fossil fuel products,” he wrote. “But Exxon Mobil is in the business of producing energy, and this is a securities fraud case, not a climate change case.”

    Pacific Coast Federation of Fishermen’s Associations v. Chevron
    On November 14, 2018, fishermen in California and Oregon filed suit against 30 companies and oil producers in Superior Court of San Francisco County. The complaint contends that the fossil fuel industry is at direct fault for global warming related damages that have negatively impacted the West Coast’s Dungeness crab fishery. The complaint contains five causes of action: nuisance, strict liability for failure to warn, strict liability for design defect, negligence, and negligent failure to warn.

    The lawsuit serves as the first-time food producers have sued the fossil fuel industry with allegations of harm to the industry. The Association alleges that the conduct of the oil companies has resulted in direct financial losses and strain to the $445 million fishing industry. In fact, in 2018, fishermen were allocated $15 million of $200 million in federal disaster relief funds after a delayed and disappointing fishing season. The complaint asserts that tax dollars should not be funding damages resulting from warming oceans created by the fossil fuel industry. Attorneys for the oil company have deemed the suit “without merit and counterproductive to real solutions on climate change.”

    Reports from the Northeast have also determined that climate impacts are directly related to the decline of species that support the most iconic fisheries in the country. These species include Atlantic cod, Atlantic sea scallops, and American lobster. This lawsuit is the first signal that the food industry will be one of the major leaders in climate change litigation.

    In re Exxon Mobil Corp. Derivative Litigation
    In August 2019, a federal judge of the US District Court for the Northern District of Texas consolidated two derivative lawsuits against ExxonMobil into a single action. The two shareholder complaints, formerly Von Colditz v. Woods and Montini v. Woods, accuse Exxon officials of lying to investors and misleading the public about the risks of climate change. The lawsuit names both current and former Exxon executives including current CEO Darren Woods and his predecessor and Former Secretary of State, Rex Tillerson.

    The shareholders accused Exxon officials of violating federal securities law, breaching fiduciary duties, and wasting corporate assets. Shareholders further alleged that the officials failed to protect their investments, misreported on the risks of climate change, failed to disclose that its Canadian oil sands were operating at a loss, and failed to disclose that carbon proxy costs were not used to calculate operating costs.

    The most recent action in this case occurred in September 2021 when Exxon filed a motion to dismiss arguing that “the independent directors on ExxonMobil’s board of directors unanimously decided in good faith, based on a reasonable inquiry, that this shareholder derivative lawsuit is not in ExxonMobil’s best interests.” Exxon also argued that the plaintiffs’ core allegations were reliant on “discredited” theories put forth in an action filed by the Massachusetts Attorney General in October 2019 and New York Attorney General’s fraud action against Exxon Mobil which had been dismissed by New York State Court.

    In re Exxon Mobil Corp. Derivative Litigation
    On August 6, 2019, a group of Exxon shareholders filed a derivative lawsuit against Exxon Mobil Corporation directors and officials. The complaint was filed in Federal District Court in New Jersey. Those named include CEO and Chairman of the Board Darren Woods, Former Chief Executive Rex Tillerson, Principal Financial Officer and SVP Andrew Singer, and other members of Exxon’s auditing committee. Demanding a jury trial, the shareholders sued Exxon and its officers for “breach of fiduciary duty, waste of corporate assets, unjust enrichment, and violations of the federal securities laws.”

    Saratoga alleges that the officers “knew, were reckless, or were grossly negligent in not knowing” that Exxon was misleading its investors regarding the risks of climate change to its business. They also allege that the officials received excessive compensation and benefits while the company failed to accurately value its reserves. This claim regards an investigation by the New York State Attorney General into how Exxon reported its climate change risk. The investigation found that Exxon kept two separate books for accounting for potential costs of greenhouse gas regulations. One was made public and submitted to the Securities and Exchange Commission (SEC), while the other was kept for internal accounting purposes.

    The complaint included the allegation that members of Exxon’s auditing committee “completely and utterly failed in their duty of oversight and failed in their duty” to review and correct the company’s accounting disclosures. The complaint also asserted that the defendants’ actions “irreparably damaged Exxon’s corporate image and goodwill.”

    In April 2020, Exxon filed a motion to transfer the case to the Northern District of Texas where two other pending cases, a putative federal securities class action suit and a consolidated federal derivative action, raised “substantially the same allegations and same causes of action against the same defendants,” including allegations that Exxon officers made misleading statements about Exxon’s “proxy costs of carbon.” The motion to transfer was ultimately granted by the New Jersey Federal Court.

    Future Outlook

    The procedural battles over jurisdiction, which have effectively forestalled any meaningful action in the majority of U.S. climate change cases, are likely to be resolved soon when the Supreme Court decides whether it will take up landmark cases such as Suncor v. Boulder County and Honolulu v. Sunoco LP. The implications of the decisions would be far-reaching and could remove the barrier that has long been standing in the way of the lawsuits that states, cities, and counties have brought against fossil fuel giants. In the coming months, we may finally be awarded some clarity on whether the strategy driving dozens of climate lawsuits is legitimate, or whether plaintiffs need to adopt a new approach.

    Additionally, experts anticipate that the number of climate change-related cases will continue to grow. It is likely that the types of claims and defendants will become increasingly more diverse, reflecting an expanded awareness of the role that multiple actors play in the causes and solutions to climate change. Entities that act with disregard toward climate commitments and targets, or that misrepresent their products and actions to the public, are also likely to continue to face increased volumes of litigation.

    Also, in light of the increase in funding for green projects by the Inflation Reduction Act, we are likely to see a corresponding increase in litigation from a variety of stakeholders seeking to hinder progress with those projects. Jennifer Hernandez, an Environmental Lawyer based in California, commented on the prospective impact of the IRA on climate litigation, saying in part, “We’ll have more projects, because we’ll have funding to get them done, but we’ll have a lot more siting disputes. And that will present political, as well as legal, challenges to achieving the production goals that are set out.”

    Experts also expect to see a continued rise in lawsuits brought against governments and major emitters challenging an over-reliance on strategies like greenhouse gas removals or ‘negative emissions’ which are claimed to be insufficient to avoid catastrophic climate change outcomes.

    In the News

    2024

    2023

    • U.S. sues eBay over sale of harmful products - Jonathan Stempel, Reuters (09/27/2023)
      The U.S. government on Wednesday sued eBay (EBAY.O), accusing the online platform of violating the Clean Air Act and other environmental laws by allowing the sale of several harmful products, including devices that defeat automobile pollution controls.
    • California lawsuit says oil giants deceived public on climate, seeks funds for storm damage - Michael R. Blood, The Associated Press (09/16/2023)
      The state of California filed a lawsuit against some of the world’s largest oil and gas companies, claiming they deceived the public about the risks of fossil fuels now faulted for climate change-related storms and wildfires that caused billions of dollars in damage, officials said Saturday.
    • Montana youth climate ruling could set precedent for future climate litigation - Nathan Rott and Seyma Bayram, NPR (08/23/2023)
      A Montana judge's historic ruling in a climate lawsuit brought by 16 young plaintiffs could have implications for future climate litigation, legal experts say. The trial and ruling, which came during a summer rife with crippling heat waves and other climate change-fueled disasters, was a rare win for climate activists seeking support in court.
    • Judge rules in favor of Montana youths in landmark climate decision - Kate Selig, The Washington Post (08/14/2023)
      In the first ruling of its kind nationwide, a Montana state court decided Monday in favor of young people who alleged the state violated their right to a “clean and healthful environment” by promoting the use of fossil fuels. The court determined that a provision in the Montana Environmental Policy Act has harmed the state’s environment and the young plaintiffs by preventing Montana from considering the climate impacts of energy projects. The provision is accordingly unconstitutional, the court said.
    • National Grid to pay $5.38M for damages caused by Gloucester Gas Light Company - The Associated Press (07/07/2023)
      National Grid agreed to pay $5.38 million to state and federal agencies to resolve claims over environmental damage caused by the defunct Gloucester Gas Light Company, officials said Friday. Hazardous chemicals released by the plant, which operated from 1854 to 1952, contaminated soil, groundwater and sediment in Gloucester Harbor, officials said.
    • Oregon county sues oil, coal companies for $51 billion over deadly heat dome - The Associated Press (06/23/2023)
      Oregon’s most populous county is suing more than a dozen large fossil fuel companies to recover costs related to extreme weather events linked to climate change.
    • Montana officials downplay first-of-its-kind climate trial - Matthew Brown and Amy Beth Hanson, The Associated Press (06/19/2023)
      Montana officials sought to downplay a first-of-its-kind trial taking place over the state’s obligations to protect residents from climate change, saying Monday that a victory by the young plaintiffs would not change approvals for fossil fuel projects.
    • Youth environmentalists bring Montana climate case to trial after 12 years, seeking to set precedent - Matthew Brown and Amy Beth Hanson, The Associated Press (06/11/2023)
      Whether a constitutional right to a healthy, livable climate is protected by state law is at the center of a lawsuit going to trial Monday in Montana, where 16 young plaintiffs and their attorneys hope to set an important legal precedent.
    • Coastal Town Brings Mass Litigation—and an ‘Existential Threat’—to Chemical Giants - Kris Maher and Dan Frosch, The Wall Street Journal (05/31/2023)
      The small city of retirees and tourists 40 miles north of Palm Beach is at the forefront of one of the nation’s biggest environmental legal battles, over a class of chemicals known as PFAS. The fight pits hundreds of municipalities and about a dozen states against corporate giant 3M and other companies that made or sold the chemicals or firefighting foam containing them.
    • Delta Air Lines hit with lawsuit over claims of carbon neutrality - Ed Davey, The Associated Press (05/31/2023)
      A consumer class action lawsuit filed Tuesday claims Delta Air Lines inaccurately billed itself as the world’s “first carbon-neutral airline” and should pay damages. The complaint in federal court in California alleges the airline relied on carbon offsets that were largely bogus.
    • WVa governor’s family coal firm agrees to reclaim mines - John Raby, The Associated Press (01/20/2023)
      A coal company owned by the family of West Virginia Gov. Jim Justice has agreed to reclaim three large surface mines in southwestern Virginia to settle a lawsuit with environmental groups. Southern Appalachian Mountain Stewards, Appalachian Voices and the Sierra Club announced the settlement Thursday with A&G Coal Corp. Under the settlement, the reclamation of about 2,400 acres at all three sites in Wise County will be done in stages, with the final one completed by December 2025, the groups said in a statement.

       

    2022

    • Climate change lawsuits filed by Annapolis and Anne Arundel County can proceed in Maryland courts, judge says - Rebecca Ritzel, The Capital Gazette (10/10/2022)
      Did global oil companies know that fossil fuel use causes climate change while still trying to convince consumers otherwise? Attorneys representing Annapolis, Anne Arundel County and dozens of other states and municipalities believe they did, and think corporations should be on the hook to pay for mitigating the harms of warming oceans, rising temperatures and other environmental crises.
    • Exxon must face Massachusetts climate change lawsuit, court rules - Nate Raymond, Reuters (05/24/2022)
      Massachusetts' high court on Tuesday unanimously rejected Exxon Mobil Corp's bid to dismiss a lawsuit by the state's attorney general accusing the oil company of misleading consumers and investors about climate change and the dangers of using fossil fuels.
    • Climate crisis could cost US $2 trillion each year by the end of the century, White House warns - Wyatte Grantham-Philips, USA Today (04/08/2022)
      The climate crisis could cost the U.S. government $2 trillion each year – an annual federal revenue loss of 7.1% – by the end of the century, the White House said in an assessment published Monday.
    • Appeals court says US downplayed coal mine’s climate impacts - Matthew Brown, The Associated Press (04/05/2022)
      U.S. officials improperly downplayed the climate change effects from burning coal when they approved a large expansion of an underground Montana coal mine that would release an estimated 190 million tons of greenhouse gasses into the atmosphere, a court ruled.
    • Shell directors sued for ‘failing to prepare company for net zero’ - Damien Gayle, The Guardian (03/15/2022)
      The directors of Shell are being sued for failing to properly prepare the multinational oil and gas company for net zero. In what is thought to be a first-of-its-kind action, the lawsuit brought by activist shareholders claims that Shell’s 13 directors are personally liable for failing to devise a strategy in line with the Paris agreement, which aims to limit global heating to below 2C by slashing fossil fuel emissions.
    • Exxon Loses Appeal to Revive Suit Over State Climate Probes (1) - Bloomberg, Bloomberg Law News (03/15/2022)
      Exxon Mobil Corp. lost its appeal to revive a 2016 lawsuit claiming the Democratic attorneys general of New York and Massachusetts were motivated by politics when they opened investigations into the energy giant’s statements to investors about climate change.
    • California gas utility fined $10M for ratepayer money misuse - Kathleen Ronayne, The Associated Press (02/04/2022)
      A major California gas utility must pay the state nearly $10 million and reimburse customers money it improperly spent on work related to the development of energy efficient building codes.
    • Activists behind Shell climate verdict target 30 multinationals - Anthony Deutsch & Simon Jessop, Reuters (01/13/2022)
      The Dutch wing of environmental group Friends of the Earth, which won a landmark court case against Royal Dutch Shell last year, demanded 30 corporations publish plans for big cuts in greenhouse gas emissions in a campaign launched on Thursday.

       

    2021

    2020

    • Dutch climate activists take Shell to court over emissions - Mike Corder, The Associated Press (12/01/2020)
      A group of environmental organizations backed by thousands of Dutch citizens launched a civil case Tuesday against the energy giant Shell, asking a court to order the multinational to commit to reining in its carbon emissions 45% by the year 2030.
    • UK to make climate risk reports mandatory for large companies - Larry Elliott, The Guardian (11/09/2020)
      Large companies and financial institutions in the UK will have to come clean about their exposure to climate risks within five years under the terms of a tougher regime announced by the chancellor, Rishi Sunak.
    • RI climate suit to stay in state court - Alex Kuffner, Providence Journal (10/29/2020)
      A pioneering lawsuit filed by Rhode Island that seeks damages from the world’s largest oil and gas companies for the impacts of climate change is set to proceed in state court after a federal appeals panel upheld a lower court’s ruling
    • Climate Change Litigation In Brazil And Latin America: An Increasing Trend That Companies Must Be Prepared For - Luiz Gustavo Bezerra et al, Mondaq (10/07/2020)
      Climate change litigation is already a firmly established trend in North American and European countries, but it is still not widespread in Brazil and Latin America. However, recent developments—as recently as June and August 2020 in Brazil—suggest that an increase in climate-related lawsuits is just around the corner and that companies should get prepared.
    • Supreme Court will consider Big Oil’s appeal fighting Baltimore climate change lawsuit - Abby Smith, The Washington Examiner (10/02/2020)
      The Supreme Court said Friday it will review oil majors’ appeal over a case brought by Baltimore seeking billions to compensate for adapting to climate change effects.
    • Is “Silent Climate” the New “Silent Cyber” for Energy Insurers? - Franco D'Andrea, Clyde & Co (06/09/2020)
      The primary complaint by the Claimants in Juliana is that the US Government and its federal departments have allegedly known for decades that carbon dioxide production as a result of combusting materials for energy purposes (such as coal, oil and natural gas) was having a catastrophic effect on the climate.
    • Big Oil loses appeal, climate suits go to California courts - Brian Melley, The Associated Press (05/26/2020)
      Big Oil lost a pair of court battles Tuesday that could lead to trials in lawsuits by California cities and counties seeking damages for the impact of climate change.
    • Supreme Court rules beaches can be protected from sewage that flows underground - David G. Savage, Pittsburgh Post Gazette (04/23/2020)
      The Supreme Court bolstered the nation’s clean-water protections for oceans and beaches Thursday, ruling that environmentalists can sue to block discharges of sewage into the ground if those pollutants flow in significant amounts from there into the ocean.

    2019

    • New York Loses Climate Change Fraud Case Against Exxon Mobil - John Schwartz, The New York Times (12/10/2019)
      A New York state judge has handed Exxon Mobil an important victory in the civil case brought by the state’s attorney general that argued that the company had engaged in fraud through its statements about how it accounted for the costs of climate change regulation.
    • Exxon's climate-change accounting goes on trial - Irina Ivanova, CBS News (10/22/2019)
      The largest U.S. fossil fuel company goes on trial Tuesday to defend itself against charges that it lied to investors about the cost of carbon emissions to its business.
    • Exxon Is On Trial, Accused Of Misleading Investors About Risks Of Climate Change - Laurel Wamsley, NPR (10/22/2019)
      In only the second climate change trial in the U.S., Exxon Mobil goes to court Tuesday accused of defrauding shareholders and the public. New York's attorney general brought the suit, which alleges that the oil giant misrepresented how carbon regulation would affect the company's financial outlook.
    • Supreme Court Lets Climate Change Lawsuit Proceed - Adam Liptak, The New York Times (10/22/2019)
      The Supreme Court on Tuesday rejected a request from more than two dozen multinational energy companies to block a state court lawsuit brought by the city of Baltimore seeking to hold the companies accountable for their role in changing the earth’s climate.
    • Exxon trial probes how oil giant accounts for climate change - Cathy Bussewitz, Associated Press (10/21/2019)
      New York’s attorney general is accusing Exxon Mobil of lying to investors about how profitable the company will remain as governments impose stricter regulations to combat global warming.
    • Big Oil is getting sued for climate change, but some cities won’t join the legal fight - Mario Ariza, South Florida Sun Sentinel (09/21/2019)
      At least two South Florida municipalities have declined to pursue lawsuits against fossil fuel companies, but as the costs of adaptation rise along with the temperature, cities, counties and even the state of Rhode Island are increasingly taking fossil fuel producers to court.
    • 23 States Sue Trump Administration In Escalating Battle Over Emissions Standards - Colin Dwyer, NPR (09/20/2019)
      Just two days after the Trump administration revoked California's right to set its own emissions standards for automobiles, the state has fired back.
    • Volkswagen to pay up to $87 million in Australia for scandal - Rod Mcguirk, ABC News (09/16/2019)
      Volkswagen has agreed to pay up to 127 million Australian dollars ($87 million) to settle an Australian class action stemming from the 2015 diesel emissions scandal, the German automaker and a lawyer said Monday.

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