Engine Manufacturers Association and Western States Petroleum Association, Petitioners v. South Coast Air Quality Management District et al. Country/Territory United States of America Type of court National - higher court Date Apr 28, 2004 Source UNEP, InforMEA Judge ScaliaRehnquistStevensOConnorKennedyThomasGinsburgBreyerSouter Reference number 02-1343 Language English Subject Air & atmosphere Keyword Emissions Air quality/air pollution Abstract Respondent South Coast Air Quality Management District was a political subdivision of California responsible for air pollution control in the Los Angeles metropolitan area and parts of surrounding counties. It enacted six Fleet Rules that generally prohibited the purchase or lease by various public and private fleet operators of vehicles that did not comply with stringent emission requirements. The question in this case was whether these local Fleet Rules escaped pre-emption under §209(a) of the Clean Air Act (CAA), 81 Stat. 502, as renumbered and amended, 42 U. S. C. §7543(a), because they addressed the purchase of vehicles, rather than their manufacture or sale. §209 CAA prohibited 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”. The District Court was of the view that the Rules were not “standards” under §209 because they regulated only the purchase of vehicles that were otherwise certified for sale in California. The Ninth Circuit Court affirmed. The Supreme Court decided that the Fleet Rules did not escape pre-emption just because they addressed the purchase of vehicles, rather than their manufacture or sale. Neither the District Court’s interpretation of “standard” to include only regulations that compelled manufacturers to meet specified emission limits nor its resulting distinction between purchase and sales restrictions found support in the text of §209(a) or the CAA’s structure. Statutory construction had to begin with the language employed by Congress and the assumption that the ordinary meaning of that language accurately expressed the legislative purpose. According to the Court, “standard” meant what was established by authority, custom, or general consent, as a model or example.” The criteria referred to in §209 related to the emission characteristics of a vehicle or engine. This interpretation was consistent with the use of “standard” throughout Title II of the CAA. Defining “standard” to encompass only production mandates confused standards with methods of enforcing standards. Manufacturers or purchasers could be made responsible for ensuring that vehicles complied with emission standards, but the standards themselves were separate from enforcement techniques. While standards targeted vehicles and engines, standard-enforcement efforts could be directed toward manufacturers or purchasers. §246, which required federal purchasing restrictions, showed that Congress contemplated the enforcement of emission standards through purchase requirements. In addition to having no basis in the text of the statute, treating sales restrictions and purchase restrictions differently for pre-emption purposes would also make no sense. The manufacturer’s right to sell federally approved vehicles was meaningless if a purchaser did not have the right to buy them. In conclusion, the Court held that while at least certain aspects of the Fleet Rules appeared to be pre-empted, the case had to be remanded for the lower courts to address, in light of the principles articulated by the Supreme Court, questions not presented in the certiorari petition that could affect the ultimate disposition of the petitioners’ suit. Full text 02-1343.ZO.html