Juliana v. United States of America, 6:15-cv-01517

Youth plaintiffs (ages 8–19 at filing) and future generations allege the federal government’s long‑standing authorization, subsidy, and permitting of fossil fuels violates constitutional rights to a stable climate system capable of sustaining human life.
District Court originally denied defendants’ motions to dismiss, finding plaintiffs stated a substantive due process claim and had shown injury and traceability.
On interlocutory appeal the Ninth Circuit agreed plaintiffs proved injury and traceability but reversed for lack of Article III redressability, concluding the remedial injunction and supervised remedial plan plaintiffs sought was beyond a court’s power.
After the Ninth Circuit decision, the Supreme Court decided Uzuegbunam (nominal/declaratory relief can satisfy redressability for a completed violation); plaintiffs sought leave to amend to replead declaratory relief claims in light of that decision.
The District Court held the Ninth Circuit’s mandate did not bar amendment, found the proposed second amended complaint dropped the injunctive/remedial plan requests, concluded declaratory relief under the Declaratory Judgment Act (and Uzuegbunam) can satisfy redressability, and granted leave to file the second amended complaint.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Ninth Circuit mandate precludes leave to amend	Mandate was silent on leave; court may permit repleading	Mandate requires dismissal and forecloses amendment	District Court: mandate did not expressly bar amendment; leave may be considered
Whether declaratory relief alone can satisfy Article III redressability	Uzuegbunam and §2201 allow declaratory/nominal relief to provide redress for completed and ongoing violations	Declaratory relief would be speculative and insufficient to redress climate injuries	Court: declaratory relief can be substantially likely to redress and is not futile under current precedent
Whether the injunctive remedial plan plaintiffs originally sought is within Article III power	Plaintiffs removed the plan request in amended pleading; seek only declarations	Defendants previously argued the requested remedial plan required policymaking beyond judicial power	Court: Ninth Circuit found such a plan beyond Article III; plaintiffs’ removal of those requests avoids that defect
Whether amended pleading establishes Article III standing	Amended complaint pleads injury, traceability, and redressability via declaratory relief and relies on Uzuegbunam	Defendants contend standing still fails because judicial relief cannot meaningfully redress global climate change	Court: amendments cure the redressability deficiency identified by Ninth Circuit; leave to amend granted

Juliana v. United States, 947 F.3d 1159 (9th Cir. 2020) (held plaintiffs proved injury and traceability but lacked redressability for requested judicially supervised remedial plan)
Uzuegbunam v. Preczewski, 141 S. Ct. 792 (2021) (Supreme Court held nominal damages/declaratory relief can satisfy Article III redressability for completed violations)
MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118 (2007) (declaratory judgment doctrine and district court discretion to resolve legal rights)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing requirements: injury, causation, redressability)
Franklin v. Massachusetts, 505 U.S. 788 (1992) (recognizing declaratory relief may establish standing by changing legal status and increasing likelihood of redress)
Utah v. Evans, 536 U.S. 452 (2002) (declaratory relief can significantly increase likelihood of obtaining relief that redresses injury)
Duke Power Co. v. Carolina Envtl. Study Grp., Inc., 438 U.S. 59 (1978) (declaratory relief recognized as redress in constitutional challenges)
Marbury v. Madison, 5 U.S. (1 Cranch) 137 (1803) (judiciary’s authority to declare the scope of constitutional rights)