Minnesota Automobile Dealers Association v. Minnesota Pollution Control Agency

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.