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.

Iowa, Missouri, and the American Free Enterprise Chamber of Commerce filed a lawsuit in the federal district court for the Eastern District of Missouri against the New York Attorney General and the Commissioner of the New York State Department of Environmental Conservation (NYSDEC) challenging the Mandatory Greenhouse Gas Reporting Program established by NYSDEC in a rule promulgated in December 2025. The plaintiffs alleged that New York’s rule imposes reporting requirements, compliance costs, and potential criminal and civil penalties for activity occurring outside New York, including requirements for fuel suppliers such as ethanol and biodiesel producers and distributors to report the amount of liquid fuel that may be sold in New York regardless of where the initial sale or production occurs. The complaint asserted that New York’s rule violated the U.S. Constitution’s prohibition on extraterritorial state regulation and was preempted by the Clean Air Act. They also asserted that the rule violated the due process rights of persons and companies by subjecting them to regulatory jurisdiction even though they lack “minimum contacts” with New York related to the conduct subject to the rule. In addition, they asserted that the rule violated the Fourth Amendment’s prohibition on unreasonable searches by authorizing NYSDEC to conduct warrantless inspection of real property at which an emission source exists.