## Facts

- Steel Company operated a Chicago manufacturing facility that used specified hazardous and toxic chemicals.
- Federal law required qualifying facilities to file annual hazardous chemical inventory forms and toxic chemical release forms with state and local authorities.
- An environmental organization alleged Steel Co. failed, over multiple years beginning in 1988, to file required reports on time and sometimes not at all, causing informational and related harms to its members.
- Before the suit was acted upon, Steel Co. had submitted all overdue reports and was in compliance.
- The organization sought declaratory relief, injunctive relief, civil penalties payable to the U.S. Treasury, and attorney’s fees.

## Issues

1. Whether plaintiffs had Article III standing to seek declaratory relief, injunctive relief, and civil penalties for fully cured, past reporting violations.
2. Whether the EPCRA citizen-suit provision authorizes suits for purely past violations when the defendant is in compliance at the time of suit.

## Decision

- The Supreme Court held the plaintiffs lacked Article III standing because the requested relief would not likely redress the alleged injuries.
- Declaratory and injunctive relief could not remedy past informational or environmental harms where compliance had already been achieved before the case proceeded.
- Civil penalties payable to the government did not redress plaintiffs’ injuries where their asserted benefit was only deterrence or satisfaction from enforcement.
- The Court rejected “hypothetical jurisdiction,” requiring courts to confirm jurisdiction (including standing) before reaching the merits.
- Because jurisdiction was absent, the Court did not decide whether EPCRA authorizes citizen suits for purely past violations.

## Legal Principles

- Federal courts must resolve Article III jurisdiction as a threshold matter and may not assume jurisdiction to reach the merits.
- Article III standing requires injury in fact, causation, and redressability; redressability demands relief that is likely to remedy the plaintiff’s injury.
- Forward-looking relief (injunction or declaration) generally does not redress injuries from violations that were fully cured before the court can act.
- Civil penalties payable to the Treasury, justified only as general deterrence or plaintiff satisfaction, do not by themselves establish redressability.
- A statutory merits dispute is not jurisdictional merely because it concerns the scope of a cause of action; jurisdiction is defeated only by claims that are wholly insubstantial or frivolous.

## Conclusion

The Court dismissed the case for lack of Article III standing because none of the requested remedies—injunctive or declaratory relief after compliance, or civil penalties payable to the government—was likely to redress the plaintiffs’ alleged injuries from past, cured reporting violations, and the Court therefore did not reach the statutory question about suits for purely past EPCRA violations.


Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (1998)