4.2 Supremacy Clause The Clean Air Act, a federal statute, establishes national

Question

4.2 Supremacy Clause The Clean Air Act, a federal statute, establishes national air pollution standards for fleet vehicles such as buses, taxicabs, and trucks. The South Coast Air Quality Management District (South Coast) is a political entity of the state of California. South Coast establishes air pollution standards for the Los Angeles, California, metropolitan area. South Coast enacted fleet rules that prohibited the purchase or lease by public and private fleet operators of vehicles that do not meet stringent air pollution standards set by South Coast. South Coast’s fleet emission standards are more stringent than those set by the federal Clean Air Act. The Engine Manufacturers Association (Association), a trade association that represents manufacturers and sellers of vehicles, sued South Coast, claiming that South Coast’s fleet rules are preempted by the federal Clean Air Act. The U.S. District Court and the U.S. Court of Appeals upheld South Coast’s fleet rules. The Association appealed to the U.S. Supreme Court. Are South Coast’s fleet rules preempted by the federal Clean Air Act? Engine Manufacturers Association v. South Coast Air Quality Management District, 541 U.S. 246, 124 S.Ct. 1756, 158 L.Ed.2d 529, Web 2004 U.S. Lexis 3232 (Supreme Court of the United States)

Explanation / Answer

NGINE MANUFACTURERS ASSOCIATION et al. v. SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT et al.

certiorari to the united states court of appeals for the ninth circuit

No. 02–1343. Argued January 14, 2004—Decided April 28, 2004

Respondent South Coast Air Quality Management District (District)—the California subdivision responsible for air pollution control in the Los Angeles metropolitan area—enacted six Fleet Rules prohibiting the purchase or lease by various public and private fleet operators of vehicles that do not comply with requirements in the Rules. Petitioner Engine Manufacturers Association sued the District and its officials, claiming that the Fleet Rules were pre-empted by §209 of the federal Clean Air Act (CAA), which prohibits the adoption or attempted enforcement of any state or local “standard relating to the control of emissions from new motor vehicles or new motor vehicle engines,” 42 U. S. C. §7543(a). In upholding the Rules, the District Court found that they were not “standard[s]” under §209 because they regulate only the purchase of vehicles that are otherwise certified for sale in California, and distinguished decisions of the First and Second Circuits pre-empting similar state laws as involving a restriction on vehicle sales rather than vehicle purchases. The Ninth Circuit affirmed.

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