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Diamond Alternative Energy LLC v. Environmental Protection Agency

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Supreme Court of the United States
Diamond Alternative Energy LLC v. Environmental Protection Agency
Term: 2024
Important Dates
Argued: April 23, 2025
Decided June 20, 2025
Outcome
reversed and remanded
Vote
7–2
Majority
Brett KavanaughChief Justice John RobertsClarence ThomasSamuel AlitoElena KaganNeil GorsuchAmy Coney Barrett
Dissenting
Sonia SotomayorKetanji Brown Jackson

Diamond Alternative Energy LLC v. Environmental Protection Agency is a case involving a challenge to the Environmental Protection Agency's authority to grant California a waiver under the Clean Air Act, allowing the state to impose its own greenhouse gas emissions standards and electric vehicle mandates for new vehicles. At its core, the case centers on broader questions about the reach of the modern administrative state—specifically, the limits of agency power, the judicial standards for establishing standing to challenge regulatory decisions, and the evolving balance of authority between federal and state governments.

The case was decided by the Supreme Court of the United States on June 20, 2025. The case was argued on April 23, 2025, during the Court's October 2024-2025 term.[1]

In a 7–2 opinion, the United States Supreme Court reversed and remanded the judgment of the United States Court of Appeals for the District of Columbia Circuit holding that the fuel producers had Article III standing to challenge EPA’s approval of California’s vehicle emissions regulations.[1] The Court concluded that even when a plaintiff is not directly regulated, standing can be established through the predictable economic effects that regulations have on third parties. It emphasized that “commonsense economic principles” and record evidence were sufficient to show that invalidating the EPA's waiver would likely increase gasoline vehicle production and thus fuel sales. The ruling lowers the evidentiary threshold for demonstrating redressability in administrative law cases, making it easier for indirectly affected parties—such as industry competitors—to bring legal challenges to agency action.[1]

HIGHLIGHTS
  • The issue: The case concerned "whether a party may establish the redressability component of Article III standing by relying on the coercive and predictable effects of regulation on third parties." Click here to learn more about the case's background.
  • The questions presented: "1. Whether a party may establish the redressability component of Article III standing by relying on the coercive and predictable effects of regulation on third parties.

    2. Whether EPA's preemption waiver for California's greenhouse-gas emission standards and zero-emission- vehicle mandate is unlawful."[2]

  • The outcome: The U.S. Supreme Court reversed the judgment of the D.C. Circuit and remanded the case for further proceedings.[1]

  • The case came on a writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit. To review the lower court's opinion, click here.

    Why it matters: The ruling expands who can challenge federal agency actions by affirming that plaintiffs may establish standing based on the predictable economic effects of regulations on third parties. This decision lowers the barrier to accessing the courts in administrative law cases and may open the door to broader industry challenges of environmental and other regulatory programs. It also signals the Court’s continued skepticism toward expansive administrative power and reflects ongoing tension over federalism, agency discretion, and judicial oversight.

    Background

    Administrative State
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    Five Pillars of the Administrative State
    Judicial deference
    Nondelegation
    Executive control
    Procedural rights
    Agency dynamics

    Click here for more coverage of the administrative state on Ballotpedia

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Diamond Alternative Energy, LLC, et al.
      • Legal counsel: Jeffrey B. Wall (Sullivan & Cromwell LLP)
    • Respondent: Environmental Protection Agency, et al.
      • Legal counsel: Ian Michael Fein (Natural Resources Defense Council), Joshua A. Klein (California Department of Justice), D. John Sauer (United States Solicitor General)

    The following summary of the case was published by Oyez

    In 2012, California applied for a waiver from the Environmental Protection Agency (EPA) to implement its Advanced Clean Car Program, which included two key components: a Low Emission Vehicle Program to reduce carbon dioxide emissions by 34% for new cars in Model Years 2017-2025, and a Zero Emission Vehicle Program requiring about 15% of manufacturers’ fleets to be electric cars by 2025. The EPA granted this waiver in 2013, and automobile manufacturers began investing to meet these requirements.

    However, in 2019, under a different administration, the EPA withdrew the 2013 waiver, arguing that state greenhouse gas regulations were preempted by federal fuel economy standards, that California’s standards weren’t necessary to meet “compelling and extraordinary conditions,” and that California could not show a direct connection between greenhouse gas emissions and its air pollution problems. After this withdrawal, several automakers like Honda, Ford, and BMW voluntarily agreed to continue meeting California’s standards due to their existing investments and growing consumer demand for electric vehicles. In 2022, under yet another administration, the EPA reversed course again and reinstated the 2013 waiver, prompting challenges from various states and fuel industry groups who argued that California should not receive special treatment and that climate change is not a “compelling and extraordinary condition” justifying state-specific standards. California, environmental organizations, and automobile manufacturers intervened to defend the EPA’s decision.

    The D.C. Circuit dismissed most of the claims for lack of standing, finding that challengers had not shown that their injuries were redressable by a favorable decision.[4]

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    • June 20, 2025: The U.S. Supreme Court reversed the judgment of the D.C. Circuit and remanded the case for further proceedings.[1]
    • April 23, 2025: The U.S. Supreme Court heard oral argument.
    • December 13, 2024: The U.S. Supreme Court agreed to hear the case.
    • July 2, 2024: Diamond Alternative Energy, LLC, et al. appealed to the U.S. Supreme Court.
    • April 9, 2023: The United States Court of Appeals for the District of Columbia Circuit held that fuel petitioners did not have a legal right to challenge California’s waiver from federal preemption to set its own vehicle-emission standards.

    Questions presented

    The petitioner presented two questions to the court, but only the following was granted certiorari:[2]

    Questions presented:
    1. Whether a party may establish the redressability component of Article III standing by

    relying on the coercive and predictable effects of regulation on third parties.[4]

    Oral argument

    Audio

    Audio of oral argument:[5]



    Transcript

    Transcript of oral argument:[6]

    Outcome

    In a 7–2 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the District of Columbia Circuit, holding the fuel producers had Article III standing to challenge EPA’s approval of the California regulations. Justice Brett Kavanaugh delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]

    The government generally may not target a business or industry through stringent and allegedly unlawful regulation, and then evade the resulting lawsuits by claiming that the targets of its regulation should be locked out of court as unaffected bystanders. [4]

    —Justice Brett Kavanaugh

    Dissenting opinion

    Justices Sonia Sotomayor and Ketanji Brown Jackson each filed separate dissenting opinions.

    In her dissent, Justice Ketanji Brown Jackson wrote:[1]

    But standing doctrine cannot serve that important purpose if the Judiciary fails to apply it evenhandedly. When courts adjust standing requirements to let certain litigants challenge the actions of the political branches but preclude suits by others with similar injuries, standing doctrine cannot perform its constraining function. [4]

    —Justice Ketanji Brown Jackson

    In her dissent, Justice Sonia Sotomayor wrote:[1]

    For reasons unknown, the majority instead conjures up a ‘heightened “proof of redressability” requirement’ that the D. C. Circuit did not adopt and that no party advanced, and then laboriously ‘decline[s] to adopt’ that requirement. [4]

    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.


    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]


    See also

    External links

    Footnotes