139 S. Ct. 452
U.S.2018Background
- Plaintiffs sued the United States alleging constitutional rights (substantive due process and equal protection) to certain climate conditions and seeking a "national remedial plan" to stabilize climate and restore Earth’s energy balance.
- The District Court denied the Government's dispositive motions, describing the claims as unusually broad constitutional allegations tied to devastating planetary harm (Juliana v. United States, 217 F. Supp. 3d 1224).
- The District Court declined to certify interlocutory review under 28 U.S.C. § 1292(b); the breadth of the claims presented substantial grounds for difference of opinion was noted by the Supreme Court.
- The Government sought a stay of District Court proceedings from the Supreme Court pending its mandamus petition (No. 18-505) asking dismissal of the suit.
- The Government argued the case exceeded Article III limits and raised unprecedented legal theories warranting mandamus and a stay.
- The Ninth Circuit had twice denied the Government mandamus relief without prejudice, citing the early stage of litigation and potential narrowing of claims; trial had been scheduled but was stayed administratively.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a stay pending Supreme Court disposition of a mandamus petition is warranted | Juliana sought to proceed in district court to resolve constitutional claims and obtain remedial relief | Government argued Supreme Court should stay district proceedings because mandamus should be granted to dismiss as beyond Article III and based on novel theories | Stay denied without prejudice because adequate relief may be available in the Ninth Circuit; mandamus in Supreme Court not likely given alternative appellate remedies |
| Whether mandamus is appropriate to confine the district court to lawful jurisdiction | Plaintiffs argued district court has authority to hear constitutional claims and craft remedies | Government argued mandamus is appropriate because claims are unprecedented and outside Article III power | Mandamus not shown to have a "fair prospect" of success in the Supreme Court here because intermediate appellate review remains available |
| Whether the Government has shown irreparable harm from denial of a stay | Plaintiffs argued proceeding in district court is necessary and not irreparably harmful to Government | Government asserted proceeding would cause irreparable harm by forcing resolution of claims that allegedly exceed judicial power | Court found Government did not meet stay standard primarily because alternative relief in the Ninth Circuit remains available |
Key Cases Cited
- Hollingsworth v. Perry, 558 U.S. 183 (stay/mandamus standards; mandamus prerequisites)
- Cheney v. United States Dist. Court for D.C., 542 U.S. 367 (mandamus standards and appropriateness)
- Roche v. Evaporated Milk Assn., 319 U.S. 21 (writ in aid of appellate jurisdiction)
- Ex parte Peru, 318 U.S. 578 (mandamus ordinarily sought in intermediate appellate court)
- Juliana v. United States, 217 F. Supp. 3d 1224 (D. Ore. 2016) (district court decision describing plaintiffs' climate-based constitutional claims)
