Rocky Mountain Farmers Union v. Corey

摘要

Trade associations may not bring claims seeking recalculation of credits previously assigned under California low carbon fuel standard if federal court finds standard is preempted by Clean Air Act renewable fuel standard or violates commerce clause of U.S. Constitution, because, even though claims are not moot: (1) recalculation would require individualized determinations of how much associations' members overpaid requiring participation of individual members and removing associational standing from associations to bring claims, and (2) even though Eleventh Amendment of U.S. Constitution only bars claims for past conduct that allegedly exclusively violated federal law in past and not for conduct in past that has ongoing or future effect, federal district court determines that claims should be barred as inequitable and impractical as remedy would involve recalculating millions of credits that have been bought by numerous parties most of which are not party to litigation.