Juliana v. United States was a federal lawsuit in which twenty-one young people argued that the U.S. government violated their constitutional rights by knowingly promoting fossil fuel use despite decades of evidence that it destabilizes the climate. Filed in the District of Oregon in 2015 and backed by the nonprofit Our Children’s Trust, the case reached the Ninth Circuit, which ordered it dismissed for lack of standing. The Supreme Court declined to review that decision on March 24, 2025, ending the litigation after nearly a decade.1The Climate Litigation Database. Juliana v. United States
Who Sued and What They Claimed
The plaintiffs were between eight and nineteen years old when the complaint was filed. Each described a personal injury tied to climate change: flooding, wildfire smoke, drought, rising seas, or damage to resources they relied on for food, water, or cultural practices. They sued alongside the environmental group Earth Guardians, naming the United States, the President, and several federal agencies as defendants.2United States Court of Appeals for the Ninth Circuit. Juliana v. United States The case was docketed in the U.S. District Court for the District of Oregon as 6:15-cv-01517.
The complaint didn’t challenge a single regulation. It challenged the entire arc of federal energy policy, alleging that the government had known about the dangers of carbon dioxide emissions for more than fifty years and continued promoting fossil fuels anyway.3LSU Law. Juliana v. United States, No. 6:15-CV-01517-TC The plaintiffs raised four legal theories: a substantive due process claim under the Fifth Amendment, an equal protection claim also under the Fifth Amendment, a Ninth Amendment claim, and a public trust doctrine claim.2United States Court of Appeals for the Ninth Circuit. Juliana v. United States
The centerpiece was the due process argument. The plaintiffs asked the courts to recognize a fundamental right to a climate system capable of sustaining human life, a right no court had ever recognized. They leaned on the Supreme Court’s reasoning in Obergefell v. Hodges, where the Court described “liberty” under the Due Process Clause as evolving with society’s understanding. If a stable climate is a precondition for exercising every other recognized liberty, they argued, then federal policies deliberately destabilizing it violate the Constitution.
The public trust claim pushed a separate theory. Governments have long been said to hold navigable waters in trust for the public. The plaintiffs asked the courts to extend that duty to the atmosphere. That extension faced a doctrinal wall in PPL Montana, LLC v. Montana, where the Supreme Court described the public trust doctrine as primarily a matter of state law.4Justia. PPL Montana, LLC v. Montana
What the Plaintiffs Asked the Court to Do
The relief the plaintiffs sought is what ultimately doomed the case, so it’s worth understanding clearly.
First, they wanted a declaratory judgment: a court statement that the government’s fossil fuel policies violated their constitutional rights. That alone wouldn’t force policy changes, but it would create a legal baseline for future challenges.
Second, they wanted an injunction ordering the government to develop and implement a plan to phase out fossil fuel emissions and draw down excess atmospheric carbon dioxide. The target was a return to concentrations below 350 parts per million by 2100, a level scientists have identified as compatible with a stable climate.5U.S. House of Representatives. Written Testimony of Plaintiff Avery McRae Federal agencies would then have to show measurable progress under court supervision.
The declaratory piece was ambitious. The injunctive piece was extraordinary. It asked a court to oversee a national decarbonization program touching energy, transportation, land use, and foreign policy at once.
Judge Aiken’s 2016 Ruling
On November 10, 2016, U.S. District Judge Ann Aiken denied the government’s motion to dismiss. She found that a climate system capable of sustaining human life was a fundamental right under the Due Process Clause, and that the public trust doctrine was an implicit component of due process enforceable through the Constitution.2United States Court of Appeals for the Ninth Circuit. Juliana v. United States Judge Aiken also rejected the argument that the plaintiffs had to bring their claims under the Administrative Procedure Act, holding that the APA’s framework for challenging discrete agency actions could not accommodate the broad constitutional theory at stake.
No federal court had gone that far before. The ruling drew national attention and set off a years-long effort by the Department of Justice to prevent the case from ever reaching trial.
The Government’s Effort to End the Case
Between 2017 and 2024, DOJ filed at least seven petitions for writs of mandamus asking appellate courts to shut the case down before trial, along with multiple stay requests and motions for interlocutory appeal. One mandamus petition reached the Supreme Court in October 2018.6United States Department of Justice. Justice Department Statement on Juliana Case The effort spanned three administrations and both parties; the Biden DOJ pursued dismissal as forcefully as the Trump DOJ had.
Trial dates were set and then vacated. The Ninth Circuit denied mandamus in July 2018 and December 2018, then granted interlocutory appeal later the same month. Each time the case seemed to move forward, a new procedural mechanism stalled it.
The 2020 Ninth Circuit Standing Decision
On January 17, 2020, a three-judge Ninth Circuit panel reversed Judge Aiken and ordered the case dismissed for lack of Article III standing. Federal standing has three parts: a concrete injury, a causal link between the injury and the defendant’s conduct, and a likelihood that a court order can actually redress the harm.7Legal Information Institute. Standing Requirement – Overview
Writing for the majority, Judge Hurwitz found the first two prongs satisfied. The court accepted that at least some plaintiffs had suffered concrete injuries from climate change and that U.S. government fossil fuel policies were a “substantial factor” contributing to those injuries.2United States Court of Appeals for the Ninth Circuit. Juliana v. United States Those findings alone were significant. A federal appellate court accepted, as a factual matter, that U.S. policy contributes to climate harm.
The case died on redressability. The majority concluded it was “beyond the power of an Article III court to order, design, supervise, or implement the plaintiffs’ requested remedial plan” because any effective plan would require complex policy judgments belonging to Congress and the President.2United States Court of Appeals for the Ninth Circuit. Juliana v. United States The court described the conclusion as reluctant and pointed the plaintiffs to the political branches and the electorate.
Judge Staton’s Dissent
District Judge Josephine Staton, sitting by designation, dissented sharply. She wrote that the plaintiffs had brought the case “to enforce the most basic structural principal embedded in our system of liberty: that the Constitution does not condone the Nation’s willful destruction.”2United States Court of Appeals for the Ninth Circuit. Juliana v. United States She would have held that the plaintiffs had standing and could proceed to trial. Telling them to seek relief from the political branches that created the problem, in her view, was no remedy at all.
Why Redressability Was the Fatal Prong
The Juliana majority applied the redressability requirement strictly, worried that ordering a national decarbonization plan would turn federal courts into “continuing monitors of the wisdom and soundness of Executive action.” Supporters of the plaintiffs pointed out that federal courts have supervised sweeping institutional reforms before, including school desegregation and prison conditions. The majority distinguished those precedents on scale, reasoning that a climate remedial plan would require simultaneous decisions about energy production, transportation, land use, and international agreements.
Whether that scale distinction is doctrinally sound or reflects judicial discomfort with the size of the problem is one of the debates the case left behind.
How the Case Finally Ended
After the 2020 decision, the plaintiffs filed amended complaints designed to narrow the requested relief and address the redressability concern. The district court allowed some amendments to proceed. The government sought mandamus again.
In May 2024, the Ninth Circuit granted the government’s mandamus petition and ordered the district court to dismiss the plaintiffs’ second amended complaint entirely.8Climate Litigation Database. Juliana v. United States The court rejected arguments that its earlier mandate did not preclude further amendment and that intervening Supreme Court decisions had shifted the law. The plaintiffs petitioned for rehearing en banc. On July 12, 2024, every judge on the original panel voted to deny the motion, and no member of the full court requested a vote on en banc review.9The Climate Litigation Database. United States v. U.S. District Court for the District of Oregon
The plaintiffs then petitioned the Supreme Court for certiorari as Case No. 24-645. On March 24, 2025, the Court denied the petition without comment.1The Climate Litigation Database. Juliana v. United States
What Juliana Changed
The case lost, but it reshaped climate litigation. The legal arguments developed in Juliana have inspired more than sixty youth-led climate lawsuits across more than fifty countries. Two state-level cases in the United States reached outcomes the federal courts refused to grant.
In Montana, youth plaintiffs won at trial in Held v. State, and the Montana Supreme Court affirmed. The court held that a stable climate system falls within the right to a clean and healthful environment guaranteed by the Montana Constitution and struck down a state law prohibiting consideration of greenhouse gas emissions in environmental reviews.10The Climate Litigation Database. Held v. State
In Hawaii, youth plaintiffs in Navahine v. Hawaii Department of Transportation reached a settlement requiring the state to establish a greenhouse gas reduction plan, complete pedestrian and bicycle transit networks within five years, and dedicate at least $40 million to expanding electric vehicle charging infrastructure by 2030.11Office of the Governor of Hawaii. Historic Agreement Settles Navahine Climate Litigation
The state wins suggest that the rights-based theory pioneered in Juliana may travel better under state constitutions, many of which contain explicit environmental rights provisions the federal Constitution lacks. The Ninth Circuit’s own findings on injury and causation from federal fossil fuel policy also give future litigants a factual foothold to build on. Whether any federal case can clear the redressability bar remains an open question.