Steel Co. v. Citizens for a Better Environment

Supreme Court of the United States · 1998 · Federal Courts

Federal CourtsStandingSubject-Matter JurisdictionArticle IIIArticle IIIstandingredressabilityinjury in fact

Facts

EPCRA requires facilities using specified hazardous and toxic chemicals to file annual inventory and release forms by statutory deadlines. Respondent, an environmental association, gave petitioner notice in 1995 that petitioner had failed since 1988 to file required forms; after receiving notice, petitioner filed all overdue forms before respondent filed suit. Respondent then sued for declaratory and injunctive relief, civil penalties payable to the United States Treasury, and litigation costs. The complaint alleged injury from petitioner’s failure to provide timely information and the lingering effects of that failure.

Issue

Whether a federal court may reach the merits of an EPCRA citizen suit before resolving Article III jurisdiction, and whether respondent had Article III standing to maintain this action when petitioner had already filed the overdue reports before suit was filed. The Court did not reach the statutory merits question whether EPCRA authorizes suits for purely past violations.

Rule

Article III standing requires (1) injury in fact that is concrete and actual or imminent, (2) causation, and (3) redressability, meaning a likelihood that the requested relief will remedy the alleged injury. A federal court must establish jurisdiction as a threshold matter and may not assume hypothetical jurisdiction in order to decide the merits. The absence of a valid cause of action does not itself defeat subject-matter jurisdiction unless the federal claim is wholly insubstantial or frivolous.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A neighborhood health association in Toledo, Ohio, alleges that Riverbend Metals failed for years to submit federally required chemical inventory reports on time. Before the association filed suit, Riverbend submitted every overdue report. The association sues in federal court seeking only civil penalties payable to the United States Treasury.

Does the association have Article III standing?

Explanation. Article III requires injury in fact, causation, and redressability. Even assuming an informational injury, Treasury-paid civil penalties do not remedy the plaintiff’s own injury; they vindicate the public interest in law enforcement. The majority rejected the idea that satisfaction from punishment or deterrence alone satisfies redressability.