## Facts

- Twenty-one youth plaintiffs, joined by a nonprofit and a representative for future generations, sued the United States and federal officials alleging that federal policies permitting and supporting fossil-fuel extraction and use contributed to climate change.
- Plaintiffs alleged resulting harms to their lives, health, property, and future well-being, asserting violations of substantive due process, equal protection principles, the Ninth Amendment, and a federal public trust obligation related to the atmosphere and climate system.
- Plaintiffs sought declaratory relief recognizing a constitutional right to “a climate system capable of sustaining human life.”
- Plaintiffs also sought injunctive relief requiring the federal government to prepare and implement a national plan to phase out fossil-fuel emissions and reduce atmospheric CO₂ to specified levels over time.
- The district court denied the government’s motion to dismiss and allowed the case to proceed toward trial.
- On interlocutory review, the Ninth Circuit addressed Article III standing in light of the scope of relief requested.

## Issues

1. Whether the youth plaintiffs had Article III standing, particularly whether their alleged climate-change injuries were redressable by the relief sought.
2. Whether a federal court may order and supervise a comprehensive, nationwide remedial plan restructuring energy and emissions policy as an exercise of equitable power.
3. Whether separation-of-powers limits require dismissal when effective relief would depend on broad policy choices assigned to the political branches.

## Decision

- The Ninth Circuit held that plaintiffs adequately alleged concrete injuries and that federal policies could contribute to those injuries for traceability purposes.
- The court nevertheless held plaintiffs lacked Article III standing because redressability was not satisfied.
- The court reasoned that ordering the requested relief—a judicially supervised plan to phase out fossil fuels and draw down atmospheric CO₂—would exceed the constitutional authority of an Article III court.
- The court concluded that any effective response would require complex, discretionary policy decisions committed to the legislative and executive branches.
- The panel remanded with instructions to dismiss for lack of standing.

## Legal Principles

- Article III standing requires redressability; injuries are not redressable when the only effective remedy would require a federal court to assume policymaking functions reserved to the political branches.
- Federal equitable powers are limited; structural injunctions requiring ongoing judicial supervision of broad governmental programs must rest on workable legal standards and remain within judicial competence.
- A court may assume arguendo the existence of a cognizable constitutional injury yet still dismiss on standing grounds when separation-of-powers limits prevent judicial redress.

## Conclusion

The Ninth Circuit ordered dismissal for lack of Article III standing because, although plaintiffs plausibly alleged serious climate-related injuries linked in part to federal action, the sweeping structural relief sought was not judicially redressable and would require policy determinations assigned to Congress and the Executive.


Juliana v. United States, 947 F.3d 1159 (9th Cir. 2020)