Number: RS20012
Title: THE FUTURE OF CITIZEN SUITS AFTER STEEL CO. AND LAIDLAW
Authors: Robert Meltz, American Law Division 
Abstract: Two recent court decisions have called into question the viability of environmental citizen suits. In Steel Co., the Supreme Court denied plaintiff standing in a citizen suit where the defendant came into compliance after plaintiff sent its notice of intent to sue, but before it filed the complaint. Subsequently, the Fourth Circuit in Laidlaw invoked mootness doctrine to extend Steel Co. to where the citizen-suit defendant achieves compliance after the complaint is filed, but before entry of final judgment.
Pages: 6
Date: Updated January 5, 1999