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GenOn Mid-Atlantic, LLC v. Montgomery County, Maryland

Filing Date: 2010
Case Categories:
  • Constitutional Claims
    • Fourteenth Amendment
  • Constitutional Claims
    • Other Constitutional Claims
Principal Laws:
Eighth Amendment, Tax Injunction Act, Fourteenth Amendment, Maryland Constitution
Description: Challenge to county law taxing carbon dioxide emissions.
  • Mirant Mid-Atlantic, LLC v. Montgomery County
    Docket number(s): 8:10-cv-01381
    Court/Admin Entity: D. Md.
    Case Documents:
    Filing Date Type File Action Taken Summary
    07/12/2010 Judgment Final order of judgment issued dismissing action without prejudice. The County moved to dismiss. The district court granted the motion and dismissed without prejudice. 
    06/02/2010 Complaint Download Complaint filed. An electric utility filed a lawsuit against Montgomery County, Maryland, challenging its tax on local carbon dioxide emitters that effectively applied only to the utility’s coal-fired power plant. In May 2010, the county enacted a law that imposed a $5-per-ton tax on carbon dioxide emissions from stationary sources emitting more than one million tons of carbon dioxide annually. The lawsuit contended that the tax constituted a bill of attainder and that it violated the Fourteenth Amendment’s guarantee of equal protection and the Eighth Amendment’s ban on excessive fines.    
  • GenOn Mid-Atlantic, LLC v. Montgomery County, Maryland
    Docket number(s): 10-1882
    Court/Admin Entity: 4th Cir.
    Case Documents:
    Filing Date Type File Action Taken Summary
    06/20/2011 Opinion Download Opinion issued. The Fourth Circuit held that the federal Tax Injunction Act does not prevent the owner of a power plant from challenging a county excise tax on carbon dioxide emissions which is only levied on the plant. The court, overturning a district court decision which held that the county fee was a tax and the power plant was thus barred from challenging it in federal court by the Tax Injunction Act, held that the fee was actually a “punitive regulatory matter” and that single entities subject to such punitive financial strikes should be able to challenge them in federal court.

© 2023 · Sabin Center for Climate Change Law · U.S. Litigation Chart made in collaboration with Arnold & Porter Kaye Scholer LLP

The materials on this website are intended to provide a general summary of the law and do not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.