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Engine Mfrs. Ass'n v. South Coast Air Quality Management Dist.

ELR Citation: 34 ELR 20028
Nos. No. 02-1343, (U.S., 04/28/2004)

The U.S. Supreme Court held that certain aspects of local fleet rules do not escape preemption under CAA §209(a) simply because they address the purchase of vehicles rather than their manufacture or sale. The fleet rules prohibit the purchase or lease of vehicles by fleet operators that do not comply with stringent emissions controls. A district court held that the rules were not "standards" and, therefore, could not be preempted. Yet neither the district court's interpretation of "standard" to include only regulations that compel manufacturers to meet specified emission limits nor its resulting distinction between purchase and sales restrictions finds support in §209(a)'s text or the CAA's structure. A "standard relating to the control of emissions from new motor vehicles or new motor vehicle engines" per §209(a) targets vehicles and engines and does not preclude standard-enforcement efforts that can be directed toward manufacturers or purchasers. And a purchase/sale distinction makes no sense since a manufacturer's right to sell federally approved vehicles is meaningless absent a purchaser's right to buy them. The case was therefore vacated and remanded. Scalia, J., delivered the opinion of the Court, in which Rehnquist, C.J., and Stevens, O'Connor, Kennedy, Thomas, Ginsburg, and Breyer, JJ., joined. Souter, J., filed a dissenting opinion.