The Supreme Court’s October Term 2025 delivered consequential rulings for environmental law, even though environmental cases were not the central focus of the merits docket.
The Court’s decisions addressed foundational issues including federalism, separation of powers, and limits on agency authority that underpin much of environmental regulation.
State-law claims have become a major battleground, with several rulings addressing when businesses can move state-court cases into federal court and when federal law preempts state claims.
In Monsanto Co. v. Durnell, the Court held that FIFRA expressly preempts a state-law failure-to-warn claim when the claim would require a warning the EPA has not required.
That ruling carries significant implications for pesticide registrants and stakeholders throughout the agricultural supply chain by reducing litigation risk tied to FIFRA-approved labels.
In Chevron USA, Inc. v. Plaquemines Parish, Louisiana, the Court held that the federal officer removal statute permits a company sued for government-contract production to remove its case to federal court.
The Court reasoned that the statute’s use of “relating to” is broad and requires only a close and non-tenuous connection, expanding a key jurisdictional tool for energy producers and federal contractors.
In Enbridge Energy, LP v. Nessel, the Court held that the 30-day removal deadline for civil cases may not be tolled, underscoring the need for immediate removal analysis when litigation is filed in state court.
On separation of powers, the Court held in Trump v. Slaughter that it is unconstitutional for Congress to grant for-cause removal protections to principal officers in executive agencies, overruling what remained of Humphrey’s Executor v. United States.
Expanded presidential control over agency leadership could increase policy fluctuation between administrations, affecting project approvals, enforcement priorities, and settlement posture for businesses dealing with federal regulators.
In Learning Resources, Inc. v. Trump, the Court held that the International Emergency Economic Powers Act does not authorise presidential tariffs, with three justices in the majority basing the ruling on the major questions doctrine.
The major questions doctrine previously underpinned the Court’s rejection of the Clean Power Plan in West Virginia v. EPA and may continue to constrain executive authority in environmental contexts.
Turning to agency enforcement, in FCC v. AT&T, Inc., the Court declined to extend its Seventh Amendment holding from SEC v. Jarkesy to FCC forfeiture orders under the Communications Act of 1934.
In Sripetch v. SEC, the Court held that the SEC may seek equitable disgorgement without showing that investors suffered financial harm, signalling that profit-based remedies remain available to regulators.
Looking ahead to the October Term 2026, the Court will consider in Suncor Energy, Inc. v. Commissioners of Boulder County whether federal law precludes state-law claims seeking relief for injuries caused by interstate and international greenhouse-gas emissions.
That case is among the most significant environmental matters on the docket, as its outcome could reshape climate litigation nationwide by determining whether state tort law remains a viable vehicle for climate-related damages claims.
The Court will also hear Dept. of Air Force v. Prutehi Guahan, examining whether a federal agency’s submission of a RCRA permit-renewal application is a final agency action subject to judicial review under the APA and whether NEPA review is required.
In Dept. of Labor v. Sun Valley Orchards, LLC, the Court will decide whether Article III precludes the Department of Labor from adjudicating proceedings to collect monetary remedies from employers alleged to have violated H-2A worker conditions.
That decision could have broader implications for agency adjudication models across environmental, workplace-safety, energy, and natural-resource regulatory programmes well beyond the immediate labour dispute.
Businesses and legal practitioners should closely monitor these forthcoming decisions, as the Court continues to define the constitutional and procedural boundaries of federal regulatory authority.