环境保护局诉卡吕梅特什里夫波特炼油厂案

This U.S. Supreme Court case arose from the EPA's 2022 denial of 105 small refinery exemption petitions under the Clean Air Act's Renewable Fuel Standard program. The refineries challenged the denials in the Fifth Circuit, but EPA moved to transfer the suit to the D.C. Circuit, arguing the denials were nationally applicable. The Fifth Circuit retained jurisdiction, finding the actions locally applicable. The Supreme Court granted certiorari to resolve a circuit split. On June 18, 2025, the Court held 7-2 that while the denials were locally or regionally applicable, they fell within the "nationwide scope or effect" exception, requiring venue in the D.C. Circuit.

The Supreme Court vacated the Fifth Circuit's judgment and remanded. Justice Thomas delivered the majority opinion, joined by Justices Alito, Sotomayor, Kagan, Kavanaugh, Barrett, and Jackson. Justice Gorsuch filed a dissenting opinion, joined by Chief Justice Roberts. The Court held that EPA's denials were locally or regionally applicable actions, but they were based on determinations of nationwide scope or effect—specifically, EPA's interpretation of "disproportionate economic hardship" and its RIN passthrough theory. Accordingly, venue lies exclusively in the D.C. Circuit.

The central dispute was whether challenges to EPA's en masse denials of small refinery exemption petitions should be filed in the D.C. Circuit or in regional circuits. The Court addressed two questions: whether the denials were "nationally applicable" on their face, and whether they were "based on a determination of nationwide scope or effect" under 42 U.S.C. § 7607(b)(1). EPA argued its actions were nationally applicable or based on nationwide determinations like its interpretation of "disproportionate economic hardship" and RIN passthrough theory. The refineries contended the actions were individualized adjudications based on local circumstances.

The decision resolved a circuit split regarding venue for Clean Air Act challenges. It established a two-part test for determining when EPA actions are "based on a determination of nationwide scope or effect," providing clarity for future environmental litigation. The ruling channels nationally significant EPA actions to the D.C. Circuit, promoting consistent interpretation of the Renewable Fuel Standard program. Alongside the companion case Oklahoma v. EPA, the decision put several long-standing venue issues to rest. However, some gray areas remain regarding what constitutes a "determination of nationwide scope or effect".