Minnesota Automobile Dealers Association v. Minnesota Pollution Control Agency

The U.S. Supreme Court denied the Minnesota Automobile Dealers Association’s petition for writ of certiorari seeking review of a Minnesota appellate court’s decision that rejected a challenge to the Minnesota Pollution Control Agency’s adoption of California vehicle greenhouse gas emissions standards pursuant to Section 177 of the Clean Air Act. Section 117 authorizes states that have nonattainment or maintenance plans to adopt standards identical to California standards for which a waiver has been granted.

The Minnesota Automobile Dealers Association filed a petition for writ of certiorari seeking review of a Minnesota appellate court’s decision upholding a Minnesota Pollution Control Agency rule that adopted California vehicle greenhouse gas emissions standards pursuant to Section 177 of the Clean Air Act. The petition presented the question of whether Minnesota qualifies to adopt California’s vehicle emission standards pursuant to Section 177 when there are no areas in Minnesota which fail to satisfy the National Ambient Air Quality Standards. The petition argues that states “cannot use outdated technical nonattainment designations (or maintenance plans) having nothing to do with motor-vehicle emissions to justify adopting California’s motor-vehicle emissions rules.”

The Minnesota Court of Appeals upheld the Minnesota Pollution Control Agency’s (MPCA’s) Clean Car Rule, which incorporated by reference certain California motor-vehicle emission standards, including a requirement that a certain percentage of vehicles delivered for sale to Minnesota be zero emission vehicles. The appellate court held that the incorporation of California’s standards by reference did not violate the nondelegation doctrine. The court also found that the MPCA acted within its statutory authority in adopting a uniform statewide motor-vehicle emission standard and that Minnesota was an eligible state to adopt the California standards under the Clean Air Act.