People v. Exxon Mobil Corp.

The federal district court remanded to state court the State of California’s lawsuit regarding Exxon Mobil Corporation’s (ExxonMobil’s) contributions to “ever-increasing plastic pollution.” The court denied a motion to remand a similar lawsuit brought by environmental groups. Both the State and the environmental organizations’ lawsuits include allegations that ExxonMobil misled the public about the greenhouse gas reduction benefits of “advanced recycling.” In California’s case, the court rejected ExxonMobil’s contention that federal enclave jurisdiction existed “[s]imply because plastic pollution touches on federal enclaves” along California’s “waterways” and “shorelines,” as well as the contention that there was federal officer jurisdiction based on the U.S. government’s World War II-era contracts with ExxonMobil predecessors to produce rubber. The court also rejected ExxonMobil’s assertion of admiralty or maritime jurisdiction as a basis for federal jurisdiction both because such jurisdiction requires an independent basis for jurisdiction and also because it would be inapplicable.