Steel Co. v. Citizens for a Better Environment
United States Supreme Court
523 U.S. 83 (1998)
The Emergency Planning and Community Right-To-Know Act (EPCRA) requires hazardous-waste users to file annual reporting forms and allows citizen suits against operators who fail to file. Citizens for a Better Environment (CBE) (plaintiff) notified Steel Company (defendant) of its intent to sue over Steel's unfiled forms; Steel promptly filed the overdue paperwork. CBE sued anyway, seeking a declaratory judgment of past violations, inspection rights, copies of the filings, civil penalties payable to the government, and attorney's fees. The district court dismissed the suit for lack of a present violation; the Seventh Circuit reversed, holding EPCRA authorized suits over wholly past violations. The Supreme Court granted certiorari on the standing question.
Whether a plaintiff has Article III standing to bring a citizen suit under an environmental-protection statute when the relief requested would not redress the plaintiff's alleged injury.