Institute for Fisheries Resources v. Bridgestone Americas, Inc.

CourtDistrict Court, N.D. California
DecidedJuly 10, 2024
Docket3:23-cv-05748
StatusUnknown

This text of Institute for Fisheries Resources v. Bridgestone Americas, Inc. (Institute for Fisheries Resources v. Bridgestone Americas, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Institute for Fisheries Resources v. Bridgestone Americas, Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 INSTITUTE FOR FISHERIES Case No. 3:23-cv-05748-JD RESOURCES, et al., 8 Plaintiffs, ORDER RE STAY 9 v. 10 CONTINENTAL TIRE THE AMERICAS, 11 LLC, et al., Defendants. 12 13 The crux of this environmental case is whether the use of N-(1,3-dimethylbutyl)-N’- 14 phenyl-p-phenylenediamine (6PPD) in car and truck tires made by defendants resulted in road 15 runoff in the form of 6PPD-quinone (6PPD-q) that caused a “taking” of protected salmonid fish 16 species in West Coast populations under Section 9 of the Endangered Species Act, 16 U.S.C. 17 § 1361 et seq (ESA). Dkt. No. 19 (first amended complaint). The Court denied defendants’ 18 motion to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6). Dkt. No. 123. 19 This order resolves defendants’ request for a stay under the “primary jurisdiction doctrine.” Dkt. 20 No. 111. 21 Defendants say that the case involves issues that “‘have been placed within the special 22 competence of an administrative body,’” namely the Environmental Protection Agency. Id. at 5 23 (quoting United States v. Western Pac. R.R. Co., 352 U.S. 59, 63-64 (1956)). Defendants urge the 24 Court to put the case on ice pending the outcome of rulemaking proceedings for 6PPD by the EPA 25 under the Toxic Substances Control Act, 15 U.S.C. § 2601 et seq. (TSCA). 26 “Primary jurisdiction is a ‘prudential doctrine under which courts may, under appropriate 27 circumstances, determine that the initial decisionmaking responsibility should be performed by the 1 relevant agency rather than by the courts.’” Freedline v. O Organics LLC, 445 F. Supp. 3d 85, 91 2 (N.D. Cal. 2020) (quoting Syntek Semiconductor Co. v. Microchip Tech. Inc., 307 F.3d 775, 780 3 (9th Cir. 2002)). The doctrine is not jurisdictional per se, but rather serves as a prudential 4 mechanism to promote harmony and avoid undue conflict when judicial and agency concerns 5 overlap. See Clark v. Time Warner Cable, 523 F.3d 1110, 1114 (9th Cir. 2008) (citation omitted); 6 Syntek, 307 F.3d at 780. It is reserved for a “limited set of circumstances” that require “resolution 7 of an issue of first impression, or of a particularly complicated issue that Congress has committed 8 to a regulatory agency.” Clark, 523 F.3d at 1114 (internal quotation omitted). 9 To determine whether application of the primary jurisdiction doctrine is appropriate, the 10 Court may consider: “(1) the need to resolve an issue that (2) has been placed by Congress within 11 the jurisdiction of an administrative body having regulatory authority (3) pursuant to a statute that 12 subjects an industry or activity to a comprehensive regulatory authority that (4) requires expertise 13 or uniformity in administration.” Astiana v. Hain Celestial Grp., 783 F.3d 753, 760 (9th Cir. 14 2015) (quoting Syntek, 307 F.3d at 781). The decision to stay a case on the basis of primary 15 jurisdiction is entrusted to the Court’s sound discretion. Id. at 761. 16 Defendants say a stay is warranted because the EPA granted a citizen’s petition submitted 17 by Native American tribes “to adopt a rule that prohibits the manufacture, processing, use, and 18 distribution of 6PPD in and for tires.” Dkt. No. 111-3 at 15.1 Petitioners called upon the EPA to 19 initiate a rulemaking under Section 6(a) of the TSCA, which directs the agency to regulate the use 20 of chemicals that present “an unreasonable risk of injury to health or the environment.” 15 U.S.C. 21 § 2605(a); Dkt. No. 111-3 at 15. The petition was filed by Earthjustice, counsel for plaintiffs in 22 this case, and discussed the impact of 6PPD-q road runoff on protected salmonid species, among 23 other arguments presented in support of a rulemaking. See, e.g., Dkt. No. 111-3 at 11-13. The 24 EPA noted that “the data that are currently reasonably available to the EPA suggest a link between 25 6PPD use in tires and the presence of 6PPD-quinone” in streams, and granted the petition. Dkt. 26

27 1 Defendants attached the petition and the EPA letter granting it, Dkt. No. 111-4, to their motion to 1 No. 111-4 at 5. The agency stated that it would “promptly commence an appropriate rulemaking 2 proceeding under TSCA Section 6(a),” but “cannot commit to a specific rulemaking timeframe or 3 outcome.” Id. at 6. The EPA said it was aiming to publish a notice of proposed rulemaking by 4 “Fall 2024,” and to “finalize the rule before 2025.” Id. 5 Defendants contend that the petition “asserted precisely the same issues and problems that 6 are asserted in” plaintiffs’ complaint. Dkt. No. 111 at 3. It is true that, in making the case for 7 granting the petition, the tribes and counsel at Earthjustice highlighted some of the same impacts 8 on protected fish species that underlie this litigation. But as the EPA observed, it was the 9 petitioners’ burden to “present ‘the facts which it is claimed establish that it is necessary’” for the 10 agency to act, Dkt. No. 111-4 at 2, and so some degree of factual overlap is not in itself 11 particularly instructive here. 12 What matters for present purposes is that the TSCA and the ESA are different statues that 13 serve different purposes. “Congress enacted TSCA in 1976 with the express purpose of limiting 14 the public health and environmental risks associated with exposure to and release of toxic 15 chemical substances and mixtures.” America Unites for Kids v. Rousseau, 985 F.3d 1075, 1094 16 (9th Cir. 2021) (quoting Physicians Comm. for Responsible Med. v. Johnson, 436 F.3d 326, 327 17 (2d Cir. 2006)). To that end, Congress specifically assigned to the EPA the duty of regulating 18 chemicals that pose an “unreasonable risk” to human or environmental health. 15 U.S.C. § 19 2605(a). 20 Congress’s stated purposes for the ESA were “to provide a means whereby the ecosystems 21 upon which endangered species and threatened species depend may be conserved,” and “to 22 provide a program for the conservation of such species.” Tennessee Valley Authority v. Hill, 437 23 U.S. 153, 180 (1978) (quoting 16 U.S.C. § 1531(b) (1976 ed.)) (cleaned up). In furtherance of 24 these goals, Congress expressly mandated that “all Federal departments and agencies shall seek to 25 conserve endangered species and threatened species” using all necessary means and procedures. 26 Id. (quoting 16 U.S.C. § 1531(c) (1976 ed.)) (emphases in original); see also Babbitt v. Sweet 27 Home Chapter of Cmtys. for a Great Oregon, 515 U.S. 687, 699 (1995) (Congress enacted the 1 ESA “to halt and reverse the trend toward species extinction, whatever the cost.”) (internal citation 2 omitted). 3 Congress did not assign regulatory authority for Section 9 of the ESA to the EPA.

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