Friends of the Earth, Inc. v. Laidlaw Environmental Services, Inc.
Supreme Court
528 U.S. 167 (2000)
Friends of the Earth and other environmental groups (plaintiffs) sued Laidlaw Environmental Services (defendant) for violating its Clean Water Act discharge permit by emitting excess mercury; the district court found Laidlaw had come into compliance with its permit, and Laidlaw subsequently closed the facility responsible for the violations. On appeal, the court of appeals held the case moot, reasoning Laidlaw's compliance and facility closure amounted to a voluntary cessation of the violations, and the Supreme Court granted certiorari to address the mootness question.
Whether a defendant's voluntary post-suit compliance and closure of an offending facility renders a citizen suit moot, absent proof there is no reasonable chance the defendant could resume the violations.