Oklahoma v. EPA

605 U.S. 609
CourtSupreme Court of the United States
DecidedJune 18, 2025
Docket23-1067
StatusPublished

This text of 605 U.S. 609 (Oklahoma v. EPA) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oklahoma v. EPA, 605 U.S. 609 (2025).

Opinion

PRELIMINARY PRINT

Volume 605 U. S. Part 2 Pages 609–626

OFFICIAL REPORTS OF

THE SUPREME COURT June 18, 2025

REBECCA A. WOMELDORF reporter of decisions

NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2024 609

Syllabus

OKLAHOMA et al. v. ENVIRONMENTAL PROTECTION AGENCY et al. certiorari to the united states court of appeals for the tenth circuit No. 23–1067. Argued March 25, 2025—Decided June 18, 2025* The Clean Air Act (CAA) channels challenges to Environmental Protec- tion Agency (EPA) actions to the U. S. Court of Appeals for the D. C. Circuit if the actions are “nationally applicable,” and to a regional Circuit if they are “locally or regionally applicable.” 42 U. S. C. § 7607(b)(1). The CAA contains an exception for certain “locally or re- gionally applicable” actions “based on a determination of nationwide scope or effect,” which also must be brought in the D. C. Circuit. Ibid. In 2015, EPA revised the national ambient air quality standards (NAAQS) for ozone to be more stringent. Each State submitted a state implementation plan (SIP) detailing how it would comply with the CAA's “Good Neighbor” provision, which requires SIPs to “contain ade- quate provisions” “prohibiting” in-state emissions activity that would interfere with other States' NAAQS compliance. § 7410(a)(2)(D)(i)(I). EPA ultimately disapproved 21 States' SIPs for failure to comply with the Good Neighbor provision. These States had asserted they did not need to propose new emissions-reduction measures, but EPA disagreed after considering the “contents of each individual state's submission” “on its own merits” and making individual determinations for each SIP. 88 Fed. Reg. 9354. EPA aggregated its disapprovals into one omnibus Federal Register rule describing EPA's “4-step framework” for evaluating SIP submis- sions. EPA asserted in the rule that its disapprovals would be review- able only in the D. C. Circuit as either nationally applicable actions or, alternatively, as locally or regionally applicable actions falling within the “nationwide scope or effect” exception based on EPA's use of “the same, nationally consistent 4-step . . . framework” and its evaluation for “national consistency.” Id., at 9380–9381. States and industry petitioners challenged EPA's SIP disapprovals in regional Circuits. Of fve Circuits to resolve EPA's motions to dismiss or transfer, four found regional Circuit review proper. Only the Tenth Circuit disagreed, granting EPA's motion to transfer suits by Oklahoma

*Together with No. 23–1068, PacifCorp et al. v. Environmental Protec- tion Agency et al., also on certiorari to the same court. 610 OKLAHOMA v. EPA

and Utah. The Tenth Circuit concluded that EPA's omnibus rule consti- tuted a single, nationally applicable action because it covered “21 states across the country” and refected EPA's application of “a uniform statu- tory interpretation and common analytical methods.” 93 F. 4th 1262, 1266. Held: EPA's disapprovals of the Oklahoma and Utah SIPs are locally or re- gionally applicable actions reviewable in a regional Circuit. Pp. 618–625. (a) Applying the framework from EPA v. Calumet Shreveport Refn- ing, L.L.C., 605 U. S. 627, venue determination under § 7607(b)(1) re- quires a two-step inquiry. First, courts identify the relevant EPA “ac- tion” and ask whether it is “nationally applicable” or only “locally or regionally applicable.” If nationally applicable, challenges belong in the D. C. Circuit. If locally or regionally applicable, courts proceed to the second step to determine whether the “nationwide scope or effect” exception applies to override the default rule of regional Circuit review. An “action” under § 7607(b)(1) is a “particular exercis[e] of EPA au- thority undertaken pursuant to [a] particular CAA provisio[n].” Id., at 637. Courts determine the relevant “action” by reference to the CAA provision under which EPA acted, not how EPA presented its decision. Each EPA SIP approval constitutes its own “action.” Section 7607(b)(1) enumerates an individual SIP approval as an example of a locally or regionally applicable action, referring expressly to EPA's “ac- tion in approving . . . any implementation plan under section 7410.” It follows that each EPA SIP disapproval is also its own action, since EPA undertakes SIP disapprovals pursuant to the same CAA authority un- derlying SIP approvals. Section 7410 directs each State to adopt and submit a plan for NAAQS implementation and directs EPA to either approve or disapprove it. Thus, EPA's approvals and disapprovals are opposite sides of the same coin. The two SIP disapprovals here are undisputedly locally or regionally applicable actions. A SIP is a state-specifc plan, so an EPA disap- proval on its face applies only to the State that proposed the SIP. An EPA decision on an individual SIP “is the prototypical `locally or region- ally applicable' action.” American Road & Transp. Builders Assn. v. EPA, 705 F. 3d 453, 455. Pp. 618–620. (b) EPA's and the Tenth Circuit's contrary arguments fail. Section 7607(b)(1) “makes the CAA's framing of the relevant `action' controlling, regardless of how EPA chooses to package its decisions in the Federal Register.” Calumet, 605 U. S., at 638. Although EPA was free to ag- gregate its SIP disapprovals into one rule, that aggregation has no sig- nifcance for venue purposes. The Tenth Circuit's view that EPA's “ac- tion” is whatever it has “chosen to issue,” 93 F. 4th, at 1267, fails to Cite as: 605 U. S. 609 (2025) 611

grapple with what § 7607(b)(1) means by “action,” which is defned by reference to the underlying CAA provision, not EPA's stylization, Calu- met, 605 U. S., at 637. The Tenth Circuit also erred in deeming EPA's actions nationally ap- plicable based on EPA's use of “uniform statutory interpretation and common analytical methods.” 93 F. 4th, at 1266. The “applicability” of an action turns on its formal geographical scope. An action “applies” nationally only if, on its face, it has binding effect throughout the coun- try. Calumet, 605 U. S., at 638–639. EPA's interpretive and analytical methodology goes to its underlying reasoning, which matters only at the second § 7607(b)(1) step. Pp. 621–622. (c) Because EPA's SIP disapprovals are locally or regionally applica- ble, the Court must determine whether the “nationwide scope or effect” exception applies. This exception requires that (1) the action “is based on a determination of nationwide scope or effect,” and (2) EPA “fnds and publishes that such action is based on such a determination.” § 7607(b)(1). The second requirement is satisfed because EPA included an express fnding in its Federal Register notice. The Court holds that EPA's SIP disapprovals were not based on any determination of nation- wide scope or effect. This requirement is met only if “a justifcation of nationwide breadth is the primary explanation for and driver of EPA's action.” Calumet, 605 U. S., at 645. Such a justifcation “does not rise to this level if EPA also relied in signifcant part on other, `intensely factual' considerations, or if the key driver of EPA's action is otherwise debatable.” Ibid. EPA's disapprovals fall into the latter category. EPA's omnibus rule makes clear that its SIP disapprovals were based on “a number of intensely factual determinations” particular to each State.

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Bluebook (online)
605 U.S. 609, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oklahoma-v-epa-scotus-2025.