Little Manila Rising v. United States Environmental Protection Agency

Background

Little Manila Rising, Medical Advocates for Healthy Air, and the Sierra Club sued the United States Environmental Protection Agency, former EPA Administrator Michael Regan, and Regional Administrator Martha Guzman Aceves under the Clean Air Act. The case involved two claims; the defendants moved to dismiss only the first claim.

The first claim alleged that the EPA failed to make a required determination by June 30, 2024, about whether California’s San Joaquin Valley had met applicable air-quality standards. California had requested a one-year extension of the attainment deadline, and the EPA proposed and then finalized an extension to December 31, 2024. The Ninth Circuit denied the plaintiffs’ request to stay that extension, which became effective on December 19, 2024. The EPA’s resulting deadline for making the attainment determination became June 30, 2025, while the Ninth Circuit’s review of the extension remained pending.

Motion to Dismiss and Motion to Stay

The defendants argued that the first claim failed because the new deadline had not arrived and that the district court lacked jurisdiction because the claim was moot or depended on the validity of the EPA’s extension. The plaintiffs asked the court to stay the claim, arguing that the original deadline had been violated and that the Ninth Circuit might invalidate the extension.

The court agreed with the defendants. It held that the first claim depended on finding the extension invalid, and that the Ninth Circuit—not the district court—had jurisdiction to decide that issue. The court therefore concluded that it lacked jurisdiction over the first claim and dismissed Plaintiffs’ first claim for relief without prejudice. The court also denied Plaintiffs’ motion to stay. It stated that if the Ninth Circuit invalidated the extension and the EPA still failed to make the required determination, the plaintiffs could bring a mandatory-duty claim then.

Motion to Intervene

The San Joaquin Valley Unified Air Pollution Control District sought to intervene as of right only as to the first claim and took no position on the remaining claim. Because the court dismissed the claim underlying the intervention request, and because the District had not shown a significant protectable interest in the remaining claim, the court denied the motion to intervene without prejudice.

Disposition

The court granted Defendants’ motion to dismiss, denied Plaintiffs’ motion to stay, dismissed Plaintiffs’ first claim for relief without prejudice, and denied the motion to intervene without prejudice. It also reset the case-management conference from March 6, 2025, to March 11, 2025, and directed the parties to submit a joint case-management statement by March 4, 2025.