Kelsey Cascadia Rose Juliana, et al. v. United States of America, et al.

A group of young people (ages 8-19), Earth Guardians (an environmental advocacy organization), and Dr. James Hansen (as guardian for future generations) filed a civil rights action against the United States, President Barack Obama, and numerous executive agencies. Plaintiffs alleged that defendants have known for more than 50 years that carbon dioxide from burning fossil fuels was destabilizing the climate system in ways that would significantly endanger plaintiffs for millennia. Despite this knowledge, plaintiffs alleged defendants permitted, encouraged, and enabled continued fossil fuel exploitation, production, and combustion through leasing public lands, undercharging royalties, providing tax breaks, permitting imports/exports, and failing to set demanding emissions standards for power plants and transportation. Plaintiffs alleged defendants bear a higher degree of responsibility than any other individual, entity, or country for climate change. The complaint alleged specific injuries to individual plaintiffs including harm to water sources, food supplies (salmon, seafood, hazelnuts), property damage from flooding (Jayden F.'s home in Louisiana flooded with sewage in August 2016), reduced snowpack affecting recreation, and health impacts from wildfires and heat. Plaintiffs alleged the United States has produced more than 25% of global CO2 emissions between 1751-2014, and that fossil fuel combustion accounts for approximately 94% of U.S. CO2 emissions.

• Whether plaintiffs' claims present a nonjusticiable political question under Baker v. Carr
• Whether plaintiffs have Article III standing to sue (injury in fact, causation, and redressability)
• Whether plaintiffs have alleged infringement of a fundamental constitutional right
• Whether the public trust doctrine applies to the federal government
• Whether the atmosphere and territorial seas are public trust assets
• Whether federal statutes like the Clean Air Act displace common law public trust claims
• Whether plaintiffs have a cause of action to enforce public trust obligations in federal court
• Whether the government has an affirmative duty under the Due Process Clause to protect plaintiffs from climate change under the 'danger creation' exception to DeShaney

Defendants' Motion to Dismiss (doc. 27) and Intervenors' Motion to Dismiss (doc. 19) were DENIED. The case was allowed to proceed to discovery and further proceedings on both the due process and public trust claims.

The binding legal principles established are: (1) The political question doctrine does not bar constitutional challenges to federal climate policy because climate change policy is not textually committed to political branches, judicially manageable standards exist to determine constitutional violations, and courts have competence to declare rights violations even if remedy crafting is complex. (2) In climate change cases at the pleading stage, causation is adequately alleged when defendants control a substantial share of global emissions (here, 25%), distinguishing cases involving minor contributors. The injury need not be sole-sourced by defendant, and widely-shared injuries can satisfy Article III if concrete and particularized. (3) There exists a fundamental constitutional right under the Fifth Amendment Due Process Clause to a climate system capable of sustaining human life, which is implicit in ordered liberty and necessary to the exercise of other fundamental rights including life, liberty, and property. This triggers strict scrutiny review of government action. (4) The 'danger creation' exception to DeShaney can apply to federal government inaction where plaintiffs adequately allege the government knowingly created dangers through affirmative acts (fossil fuel promotion) and failed with deliberate indifference to prevent resulting harm. (5) The public trust doctrine applies to the federal government, not only to states, because public trust obligations are inherent attributes of sovereignty; the federal government holds assets like the territorial seas in trust for current and future generations. (6) Federal environmental statutes do not displace constitutional public trust claims because public trust obligations cannot be legislated away—they define inherent limits on sovereign power. (7) Plaintiffs have a cause of action under the Fifth Amendment Due Process Clause to enforce public trust rights that predate the Constitution but are secured by it, with the Fifth Amendment providing the right of action for violations.

The Court made several significant non-binding observations: (1) The Court suggested (without deciding) that the atmosphere itself may be a public trust asset, noting it was included in the Institutes of Justinian and early American cases, and that courts have held the public trust should be "molded and extended to meet changing conditions." (2) The Court noted that youth plaintiffs who cannot vote have diminished voice in representative government, drawing parallels to Baker v. Carr's vote dilution concerns, though it did not decide whether youth or future generations constitute suspect classifications. (3) Judge Aiken observed that "federal courts too often have been cautious and overly deferential in the arena of environmental law, and the world has suffered for it," citing Judge Goodwin's critique of modern justiciability barriers. (4) The Court emphasized that difficulty of proof at later stages cannot support dismissal at the pleading stage, and that climate science is "constantly evolving." (5) The Court noted the influence of Social Contract theory and intergenerational equity principles on the Founding Fathers, particularly Thomas Jefferson's view that each generation has an obligation to pass natural resources undiminished to future generations. (6) The Court stated that determining whether the atmosphere is a public trust asset was unnecessary because plaintiffs adequately alleged harm to the territorial seas, which are established public trust assets. (7) Judge Aiken emphasized that "new fundamental rights are not out of bounds" and quoted Obergefell: "The generations that wrote and ratified the Bill of Rights...did not presume to know the extent of freedom in all its dimensions."

This is a landmark decision in climate change litigation that has significant implications for environmental law, constitutional law, and the separation of powers. It is one of the first U.S. federal court decisions to: (1) recognize a fundamental constitutional right to a stable climate system capable of sustaining human life; (2) hold that the public trust doctrine applies to the federal government with respect to natural resources like the territorial seas; (3) find that youth plaintiffs have standing to challenge federal climate policy despite the global, aggregate nature of climate change; (4) reject political question doctrine defenses in the climate change context; (5) hold that the Clean Air Act and other environmental statutes do not displace constitutional public trust claims; and (6) recognize a potential 'danger creation' due process claim based on government conduct contributing to climate change. The decision represents a significant expansion of justiciability in environmental cases and recognizes intergenerational equity principles. The court explicitly rejected judicial conservatism in environmental law, citing Judge Goodwin's call for courts to take "another long and careful look at the barriers to litigation created by modern doctrines of subject-matter jurisdiction." While this is a U.S. federal court decision, it has been influential in climate litigation globally and has parallels to public trust and constitutional environmental rights developments in other jurisdictions. The case continued through appeals, with the Ninth Circuit ultimately dismissing for lack of Article III standing in 2020, though this district court opinion remains significant for its reasoning.