Murray Energy Corp. v. Pruitt

On January 8, 2018, the U.S. Supreme Court denied a petition for writ of certiorari filed by the coal company Murray Energy Corporation and related companies, in which the companies sought review of the Fourth Circuit’s dismissal of their action that sought to compel the U.S. Environmental Protection Agency (EPA) to conduct a study of the Clean Air Act’s effects on employment, particularly in the coal industry. The Fourth Circuit held that the district court lacked jurisdiction to hear the case because EPA had “considerable discretion” to decide how to manage the Clean Air Act’s statutory mandate that EPA “shall conduct continuing evaluations of potential loss or shifts of employment.”

The coal company Murray Energy Corporation and affiliated companies filed a petition for writ of certiorari asking the Supreme Court to overturn the Fourth Circuit’s dismissal of their action that sought to compel EPA to conduct a study of the Clean Air Act’s employment effects and particularly its effects on the coal industry. The Fourth Circuit concluded that courts lacked jurisdiction to review EPA’s management of the “broad, open-ended” mandate of Section 321(a) of the Clean Air Act requiring EPA to conduct evaluations of potential employment losses and shifts resulting from its administration and enforcement. The petition to the Supreme Court presented two questions: (1) whether a federal court may decline jurisdiction to compel agency action where the statutory requirements for a claim have been satisfied, and (2) whether EPA’s refusal to comply with Section 321 was within the bounds of a federal court’s authority to correct.