PAWS Holdings, LLC v. Daikin Industries, Ltd.

The federal district court for the Southern District of Georgia dismissed an action alleging that heating, ventilation, and air conditioning (HVAC) units manufactured by the defendants were defective. The plaintiff’s allegations included that the HVAC units damaged the environment by leaking a potent greenhouse gas. Among the claims dismissed were negligence and strict liability claims. The court said that an alleged injury to the environment due to emissions of greenhouse gas emissions did not provide a basis for standing to make these claims because the plaintiff—a company that installed the HVAC units in its offices—failed to allege an injury different from the common injury to the public.