West Virginia v. EPA
View Official PDFBelow are plain-language sections to help you understand what the Court decided in West Virginia v. EPA and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of West Virginia v. EPA.
The Supreme Court ruled on the authority of the Environmental Protection Agency (EPA) under the Clean Air Act to regulate carbon emissions from power plants. The Court determined that the EPA exceeded its statutory authority by implementing the Clean Power Plan, which involved generation shifting. This decision emphasizes the need for clear congressional authorization for agencies to address major economic and political issues.
Holding
The single most important “bottom line” of what the Court decided in West Virginia v. EPA.
The Court held that Congress did not grant the EPA in Section 111(d) of the Clean Air Act the authority to devise emissions caps based on the generation shifting approach.
Constitutional Concepts
These are the Constitution-related themes that appear in West Virginia v. EPA. Click a concept to see other cases that involve the same idea.
-
Why Administrative Law is relevant to West Virginia v. EPA
The case primarily involves the limits of agency authority under the major questions doctrine, which is a principle of administrative law.
Syllabus excerpt (verbatim)The major questions doctrine seeks to protect against 'unintentional, oblique, or otherwise unlikely' intrusions on these interests.
-
Why Nondelegation is relevant to West Virginia v. EPA
The Court's decision is based on the principle that Congress must clearly delegate authority for major questions, implicating the nondelegation doctrine.
Syllabus excerpt (verbatim)Under that doctrine, EPA explained, courts 'expect Congress to speak clearly if it wishes to assign to an agency decisions of vast economic and political significance.'
-
Why Standing is relevant to West Virginia v. EPA
The Court addressed whether the petitioners had standing to challenge the D.C. Circuit's decision, which is a constitutional requirement for judicial review.
Syllabus excerpt (verbatim)Here, it is apparent that at least one group of petitioners—the state petitioners—are injured by the Court of Appeals' judgment.
Key Quotes
Short excerpts from the syllabus in West Virginia v. EPA that support the summary and concepts above.
Congress did not grant EPA in Section 111(d) of the Clean Air Act the authority to devise emissions caps based on the generation shifting approach.
This is a major questions case.
The agency must point to 'clear congressional authorization' for the authority it claims.
