Iowa v. James

The court allowed the plaintiffs to file their opposition to the motion to dismiss. The plaintiffs argued that the New York officials “purposefully availed themselves of the privilege of governing” in Missouri “[b]y projecting New York’s coercive authority into Missouri.” They argued that the defendants “committed a tortious act in the jurisdictional sense,” providing a basis for personal jurisdiction and venue.

The day after the court dismissed their complaint, the plaintiffs requested leave to file an opposition to the motion to dismiss. They contended that although the court’s opinion stated that they failed to file a response to the motion to dismiss, the agreed-to briefing schedule provided for them to file their opposition by August 14.

On August 11, 2026, the federal district court for the Eastern District of Missouri granted the New York State Attorney General and New York State Department of Environmental Conservation Commissioner’s motion to dismiss for lack of personal jurisdiction a lawsuit brought by Iowa, Missouri, and the American Free Enterprise Chamber of Congress challenging New York’s greenhouse gas reporting program. The court declined to find that the New York officials were subject to general jurisdiction in Missouri and found that the plaintiffs’ allegations failed to establish that the officials had sufficient minimum contacts with Missouri to satisfy due process requirements for specific jurisdiction. The court denied an alternative motion to dismiss for lack of venue as moot.