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Parents for Future Brazil v. State Government of Sao Paulo

At issue: Whether the State of Sao Paulo must disclose climate and budget impacts of an automaking fund.
Jurisdictions:
  • Brazil
    • Court of Justice of Sao Paulo
READ MORE

Friends of the Earth et al. v. Prefect of of Bouches-du-Rhône and Total

At issue: Whether a permit to operate a biorefinery must take into account climate impacts of palm oil production and use.
Jurisdictions:
  • France
    • Administrative Court of Marseille
READ MORE

Association for Protection of Democratic Rights v. The State of West Bengal and Others

At issue: Whether the State of West Bengal may cut hundreds of trees in order to construct and widen roads.
Jurisdictions:
  • India
    • Supreme Court
READ MORE

Global Legal Action on Climate Change v. The Philippines Government

At issue: Local government officials' compliance with 1989 law relating to water provision and flood control
Jurisdictions:
  • Philippines
    • Supreme Court
READ MORE

Greenpeace Mexico v. Ministry of Energy and Others (on the National Electric System policies)

At issue: Whether National Electric System policies are unconstitutional for discriminating against renewables.
Jurisdictions:
  • Mexico
    • First Circuit Collegiate Tribunal
  • Mexico
    • District Court in Administrative Matters
READ MORE

Petition to the Inter-American Commission on Human Rights Seeking to Redress Violations of the Rights of Children in Cité Soleil, Haiti

At issue: Whether the health harms from trash disposal, exacerbated by climate change, violate Haitian children's human rights.
Jurisdictions:
  • Inter-American Commission on Human Rights
READ MORE

Hanuman Laxman Aroskar v. Union of India

At issue: Whether the Indian government's approval of a new airport adequately considered environmental impacts
Jurisdictions:
  • India
    • Supreme Court
READ MORE

Segovia et al. v. Climate Change Commission

At issue: Whether the Philippine government's Climate Change Commission violated the Philippine violated the constitution by failing to enact ambitious climate-related transportation measures.
Jurisdictions:
  • Philippines
    • Supreme Court
READ MORE

Greenpeace East Asia and others v. Ministry of Economic Affairs

At issue: Whether Taiwan's Regulation for Large Power Consumers was not sufficiently ambitious, in violation of the country's climate laws.
Jurisdictions:
  • Taiwan
    • Taipei Administrative Court
READ MORE

ClientEarth v. European Investment Bank

At issue: Whether finance decisions by the European Investment Bank may be subject to requests for internal review under the Aarhus Convention over their potential environmental harm.
Jurisdictions:
  • European Union
    • General Court (known as Court of First Instance before 2010)
READ MORE

Greenpeace Netherlands v. State of the Netherlands

At issue: Whether the Dutch government violated its duty of care to prevent dangerous climate change by failing to attach stringent climate conditions to its coronavirus bailout package of the airline KLM.
Jurisdictions:
  • Netherlands
    • The Hague
      • District Court
READ MORE

Friends of the Earth v. UK Export Finance

At issue: Whether the UK government's decision to provide financing to a liquid natural gas project in Mozambique violated climate commitments
Jurisdictions:
  • United Kingdom
    • England and Wales
      • High Court of Justice, Queen's Bench Division
READ MORE

Conservation Council of Western Australia v. Hatton and Woodside

At issue: Whether the state EPA's allowing expanded natural gas sourcing violated the state Environmental Protection Act due to environmental and climate impacts
Jurisdictions:
  • Australia
    • Western Australia
      • Supreme Court
READ MORE

KEPCO Bylong Australia v. Independent Planning Commission and Bylong Valley Protection Alliance

At issue: Whether a planning commission's rejection of a coal mine on sustainability and climate grounds was unlawful
Jurisdictions:
  • Australia
    • New South Wales
      • Land and Environment Court
READ MORE

Transport Action Network v. Secretary of State for Transport (on National Policy Statement)

At issue: Whether the UK government's national policy statement on road building must be reassessed in light of new, more ambitious climate targets
Jurisdictions:
  • United Kingdom
    • England and Wales
      • High Court of Justice, Queen's Bench Division
READ MORE

Transport Action Network v. Secretary of State for Transport and Highway England Company (on Roads Investment Strategy)

At issue: Whether the UK government's Second Roads Investment Strategy unlawfully fails to consider climate and air pollution impacts
Jurisdictions:
  • United Kingdom
    • England and Wales
      • High Court of Justice, Queen's Bench Division
READ MORE

Elliott-Smith v. Secretary of State for Business, Energy and Industrial Strategy et al.

At issue: Whether the UK Emissions Trading Scheme sets an improperly high emissions cap and unlawfully excludes incinerator emissions
Jurisdictions:
  • United Kingdom
    • England and Wales
      • High Court of Justice, Queen's Bench Division
READ MORE

Institute of Amazonian Studies v. Brazil

At issue: Whether the Brazilian Constitution guarantees a fundamental right to a stable climate and whether the Brazilian government may be compelled to meet emission and deforestation reduction goals
Jurisdictions:
  • Brazil
    • Federal District Court of Curitiba
READ MORE

Center for Food and Adequate Living Rights et al. v. Tanzania and Uganda

At issue: Whether agreements to build the East African Crude Oil Pipeline violate environmental and human rights impact assessment requirements
Jurisdictions:
  • East African Court of Justice
READ MORE

PSB et al. v. Brazil (on deforestation and human rights)

At issue: Whether Brazil's failure to curb deforestation and resulting climate change violates fundamental constitutional rights of indigenous peoples and current and future generations.
Jurisdictions:
  • Brazil
    • Federal Supreme Court
READ MORE

Thomas v. EPA

At issue: Whether environmental permit that allowed oil exploration and production for 23 years violated Guyanese environmental regulations limiting such permits to five years
Jurisdictions:
  • Guyana
    • Supreme Court
READ MORE

Greenpeace Mexico v. Ministry of Energy and Others (on the Energy Sector Program)

At issue: Whether Mexico's energy sector policy violates human rights by promoting fossil fuels at the expense of renewables
Jurisdictions:
  • Mexico
    • District Court in Administrative Matters
READ MORE

Shrestha v. Office of the Prime Minister et al.

At issue: Seeking an order to compel the government of Nepal to enact an adequate climate change law
Jurisdictions:
  • Nepal
    • Supreme Court
READ MORE

Korean Biomass Plaintiffs v. South Korea

At issue: Whether South Korea's subsidies to biomass generation violate the constitutional environmental rights of solar owners and nearby residents
Jurisdictions:
  • South Korea
    • Constitutional Court
READ MORE

Lark v. Shellharbour City Council

At issue: Plaintiff challenged climate-based conditions in building permit
Jurisdictions:
  • Australia
    • New South Wales
      • Land and Environment Court
READ MORE

Greenpeace v. Spain

At issue: Environmental groups sued Spanish government for greater climate action.
Jurisdictions:
  • Spain
    • Supreme Court
READ MORE

Carballo, et al. v. State of the Province of Buenos Aires and the Provincial Agency for Sustainable Development

At issue: Plaintiffs alleged irregularities in permitting for thermoelectric plant.
Jurisdictions:
  • Argentina
    • Administrative Court of Azul
READ MORE

Carballo et al. v. MSU S.A., UGEN S.A., & General Electric

At issue: Plaintiffs sought to block thermoelectric plant
Jurisdictions:
  • Argentina
    • Federal Court of Azul
READ MORE

OAAA v. Araucaria Energy SA.

At issue: Plaintiffs sought to block thermoelectric plant
Jurisdictions:
  • Argentina
    • Federal Court of Mercedes
READ MORE

Hahn et al. v. Araucaria Energy Sociedad Anonima

At issue: Plaintiffs sought to block thermoelectric plant
Jurisdictions:
  • Argentina
    • Federal Court of Campana
READ MORE

Hahn et al. v. APR Energy S.R.L

At issue: Plaintiffs sought to block thermoelectric plant
Jurisdictions:
  • Argentina
    • Federal Court of Campana
READ MORE

FOMEO v. MSU S.A., Rio Energy S.A., & General Electric

At issue: Petition sought to block thermoelectric plant
Jurisdictions:
  • Argentina
    • Federal Court of San Nicolás
READ MORE

Johnston v Bass Coast Shire Council

At issue: Court considered climate change in assessing development permit
Jurisdictions:
  • Australia
    • Victoria
      • Civil and Administrative Tribunal
READ MORE

Joe Davidson Town Planning v Byron Shire Council

At issue: Plaintiff sought rezoning for climate considerations
Jurisdictions:
  • Australia
    • New South Wales
      • Land and Environment Court
READ MORE

Henroth Investments Pty Ltd v Sydney North Planning Panel

At issue: Plaintiff sought zoning review
Jurisdictions:
  • Australia
    • New South Wales
      • Land and Environment Court
READ MORE

Gibson v Bass Coast Shire Council

At issue: Whether land should be subdivided to prepare for climate impacts.
Jurisdictions:
  • Australia
    • Victoria
      • Civil and Administrative Tribunal
READ MORE

Friends of Leadbeater’s Possum Inc v VicForests (No 3)

At issue: Injunction sought to halt tree clearing
Jurisdictions:
  • Australia
    • Federal Court of Australia
READ MORE

Sharma and others v. Minister for the Environment

At issue: Youth sought injunction to block coal project.
Jurisdictions:
  • Australia
    • Federal Court of Australia
READ MORE

Youth v. Government of Mexico

At issue: Youth sought climate action by federal government.
Jurisdictions:
  • Mexico
    • District Court in Administrative Matters
READ MORE

Corporation of the Canadian Civil Liberties Association v. Attorney General of Ontario

At issue: Whether local law requiring stickers on gas pumps about "carbon tax" violated free speech.
Jurisdictions:
  • Canada
    • Ontario
      • Superior Court of Justice
READ MORE

Youth for Climate Justice v. Austria, et al.

At issue: Youth filed human rights complaint against 33 governments.
Jurisdictions:
  • European Court of Human Rights
READ MORE

EH v Queensland Police Service; GS v Queensland Police Service

At issue: Whether climate protesters were unlawfully convicted for protesting coal mine.
Jurisdictions:
  • Australia
    • Queensland
      • District Court
READ MORE

Dunford v Gosford City Council

At issue: Plaintiff challenged building permit on coastal erosion grounds.
Jurisdictions:
  • Australia
    • New South Wales
      • Land and Environment Court
READ MORE

Dougherty Bros Pty Ltd v Outline Planning Consultants Pty Ltd

At issue: Plaintiffs challenged building permit on climate change grounds.
Jurisdictions:
  • Australia
    • New South Wales
      • Land and Environment Court
READ MORE

Cherry Tree Wind Farm Pty Ltd v Mitchell Shire Council

At issue: Challenge to wind farm
Jurisdictions:
  • Australia
    • Victoria
      • Civil and Administrative Tribunal
READ MORE

Charles & Howard Pty Ltd v Redland Shire Council

At issue: Plaintiff challenged building approval on climate grounds.
Jurisdictions:
  • Australia
    • Queensland
      • Planning and Environment Court
READ MORE

Australian Conservation Foundation Incorporated v Minister for the Environment and Energy

At issue: Environmental group challenged coal mine
Jurisdictions:
  • Australia
    • Federal Court of Australia
READ MORE

Australasian Centre for Corporate Responsibility (ACCR) v Commonwealth Bank of Australia

At issue: Plaintiffs sought climate disclosures
Jurisdictions:
  • Australia
    • Federal Court of Australia
READ MORE

0907346 [2009] RRTA 1168

At issue: Applicant sought protection under Refugee Act due to sea level rise.
Jurisdictions:
  • Australia
    • Refugee Review Tribunal
READ MORE

Deutsche Umwelthilfe v. Stralsund Mining Authority

At issue: Environmental group challenged natural gas pipeline permit
Jurisdictions:
  • Germany
    • Supreme administrative court of the State of Mecklenburg-Western Pomerania
READ MORE

Instituto Socioambiental et al v. IBAMA and the Federal Union

At issue: Plaintiffs sought reversal of an act issued by the federal environmental agency that eased requirements for the exportation of timber.
Jurisdictions:
  • Brazil
    • 7th Federal Environmental and Agrarian Court of the Judiciary Section of Amazonas
READ MORE

O’Donnell v. Commonwealth

At issue: Holder of Australian bonds sued government to disclose climate risks.
Jurisdictions:
  • Australia
    • Federal Court of Australia
READ MORE

Trans Mountain Pipeline ULC v. Misavair

At issue: Pipeline protesters sought to assert necessity defense
Jurisdictions:
  • Canada
    • British Columbia
      • Court of Appeal
  • Canada
    • British Columbia
      • Supreme Court
READ MORE

Asociación Civil por la Justicia Ambiental v. Province of Entre Ríos, et al.

At issue: Class action asks Argentinian Supreme Court to recognize rights of the Paraná Delta.
Jurisdictions:
  • Argentina
    • Supreme Court
READ MORE

Neubauer, et al. v. Germany

At issue: Youth argued that Germany's GHG reduction goals violated human rights.
Jurisdictions:
  • Germany
    • Federal Constitutional Court
READ MORE

Development YES – Open-Pit Mines NO v. Group PZU S.A.

At issue: Complaint brought against Polish coal company under OECD National Guidelines.
Jurisdictions:
  • Poland
    • National Point of Contact for the OECD Guidelines
READ MORE

PSB et al. v. Brazil (on Climate Fund)

At issue: Four political parties filed a Direct Action of Unconstitutional Omission to the Federal Supreme Court to compel the Ministry of the Environment to resume the activities of the Climate Fund.
Jurisdictions:
  • Brazil
    • Superior Tribunal Federal
READ MORE

PSB et al. v. Brazil (on Amazon Fund)

At issue: Four political parties filed a Direct Action of Unconstitutional Omission before the Federal Supreme Court to compel the Ministry of the Environment to resume the activities of the Amazon Fund.
Jurisdictions:
  • Brazil
    • Federal Supreme Court
READ MORE

Vince et al. v. Secretary of State for Business, Energy and Industrial Strategy et al.

At issue: Plaintiffs sought review of energy national policy statements in light of UK's new climate commitment and the Paris Agreement.
Jurisdictions:
  • United Kingdom
    • England and Wales
      • Planning Court, Queen's Bench Division
READ MORE

Ecology Action, et al. v. Minister of Environment and Climate Change

At issue: Environmental groups challenged approval of exploratory drilling, including on climate grounds
Jurisdictions:
  • Canada
    • Federal Court
READ MORE

Fridays for Future Estonia v. Eesti Energia

At issue: Environmental group challenged issuance of construction permit for an oil plant.
Jurisdictions:
  • Estonia
    • Tartu Administrative Court
READ MORE

Hearing on Climate Change Before the Inter-American Commission on Human Rights

At issue: Civil society groups asked IACHR to promote climate policies that protect human rights.
Jurisdictions:
  • Inter-American Commission on Human Rights
READ MORE

Friends of the Irish Environment v. The Government of Ireland, et al.

At issue: Whether Irish Government inadequately considered National Planning Framework's climate impacts.
Jurisdictions:
  • Ireland
    • High Court of Ireland
READ MORE

Youth Verdict v. Waratah Coal

At issue: Australian youth challenged proposed coal mine on human rights grounds.
Jurisdictions:
  • Australia
    • Queensland
      • Land Court
READ MORE

Germanwatch vs. Volkswagen

At issue: Climate impacts of Volkswagen activities
READ MORE

Norwegian Climate Network et al vs Statoil

At issue: Effect of Statoil’s investment in oil sands project in maintaining climate stability
Jurisdictions:
  • Norway
    • National Point of Contact for OECD Guidelines
READ MORE

BankTrack, et al. vs. ING Bank

At issue: Violation of OECD guidelines on climate change by ING
Jurisdictions:
  • Netherlands
    • National Point of Contact for OECD Guidelines
READ MORE

Market Forces v. SMBC, MUFG and Mizuho

At issue: Complaint against funding of coal mines in Vietnam by Japanese Banks
Jurisdictions:
  • Japan
    • National Point of Contact for OECD Guidelines
READ MORE

Bushfire Survivors for Climate Action Incorporated v. Environmental Protection Authority

At issue: Bush fire victims sought to compel greenhouse gas regulation
Jurisdictions:
  • Australia
    • New South Wales
      • Land and Environment Court
READ MORE

Packham v. Secretary of State for Transport

At issue: Halt railway project on the ground that GHGs had not been adequately considered.
Jurisdictions:
  • United Kingdom
    • England and Wales
      • Court of Appeal
  • United Kingdom
    • England and Wales
      • High Court of Justice, Queen's Bench Division
READ MORE

Non-compliance Procedure of Croatia under the Kyoto Protocol

At issue: Question of implementation relating to the calculation of Croatia’s assigned amount and commitment period reserve
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

Non-compliance Procedure of Canada under the Kyoto Protocol

At issue: Canada’s failure to establish a national registry in accordance with the guidelines and modalities
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

Non-compliance Procedure of Kazakhstan under the Kyoto Protocol

At issue: Kazakhstan’s non-compliance with requirements under Articles 5 and 7 of the Kyoto Protocol and methodological, reporting and national registry requirements and adjustments required to its 2017 submission with respect to CO2, CH4 and N2O emission estimates.
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

Non-compliance Procedure of Monaco under the Kyoto Protocol

At issue: Monaco’s non-compliance with Articles 5 and 7 of the Kyoto Protocol in relation to its annual submission.
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

Non-compliance Procedure of Ukraine under the Kyoto Protocol II

At issue: Ukraine’s failure to establish a true-up period report demonstrating compliance with the Kyoto Protocol
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

Non-compliance Procedure of Slovakia under the Kyoto Protocol

At issue: Slovakia’s failure to establish an initial report demonstrating compliance with the Kyoto Protocol
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

Non-compliance Procedure of Lithuania under the Kyoto Protocol

At issue: Lithuania’s failure to establish an initial report demonstrating its capacity to account for emissions in compliance with guidelines under the Kyoto Protocol
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

Non-compliance Procedure of Ukraine under the Kyoto Protocol

At issue: Ukraine’s failure to establish an initial report demonstrating compliance of its national systems with the procedures under the Kyoto Protocol.
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

IPC Petroleum France SA v. France

At issue: Whether placing an eventual expiration date on a fossil fuel mining permit in service of national mitigation goals violates the permit holder’s right to peaceful enjoyment of property.
Jurisdictions:
  • France
    • Administrative Supreme Court
READ MORE

Society for the Protection of Landscapes and Aesthetics of France et al. v. The Mills of Lohan

At issue: Challenge to a wind farm expected to harm protected species
Jurisdictions:
  • France
    • Administrative Court of Appeal
  • France
    • Nantes
READ MORE

Non-compliance Procedure of Romania under the Kyoto Protocol

At issue: Romania’s failure to establish an initial report demonstrating compliance of its national systems with the procedures under the Kyoto Protocol.
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

In re Court on its own motion v. State of Himachal Pradesh and others

At issue: Court on its own motion issued restrictions to curb black carbon emissions, among other things.
Jurisdictions:
  • India
    • National Green Tribunal
READ MORE

Federal Environmental Agency (IBAMA) v. Siderúrgica São Luiz Ltd. and Martins

At issue: Brazil seeks to hold a steel company and its manager liable for environmental damages (promoting illegal deforestation) and climate damages (greenhouse gases derived from the illegally sourced coal)
Jurisdictions:
  • Brazil
    • 15th Civil Federal Court
READ MORE

Non-compliance Procedure of Bulgaria under the Kyoto Protocol

At issue: Bulgaria’s failure to establish an initial report demonstrating its capacity to account for emissions
Jurisdictions:
  • United Nations Framework Convention on Climate Change
READ MORE

PPC Power v Slovak Financial Directorate

At issue: Interpretation of Article 1 of Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the European Community, in the context of the advance payment of tax on greenhouse gas emission allowances allocated free of charge which have not been used or have been transferred.
Jurisdictions:
  • European Union
    • European Court of Justice
READ MORE

Evonik Degussa GmbH v Republic of Germany

At issue: Interpretation of Decision 2011/278, to determine whether free greenhouse gas emission allowances should be awarded in the context of implementing a process of separation of hydrogen in a rich gas stream which already contains hydrogen.
Jurisdictions:
  • European Union
    • European Court of Justice
READ MORE

Saint-Gobain Glass Deutschland GmbH v European Commission

At issue: Saint-Gobain challenged the decision of the European Commission refusing access to the information of the Federal Environment Agency of the Federal Republic of Germany relating to Saint-Gobain’s installations in Germany.
Jurisdictions:
  • European Union
    • European Court of Justice
READ MORE

INEOS Köln GmbH v Republic of Germany

At issue: INEOS challenged national provision, derived from Directive 2003/87/CE, establishing a time limit for applying for free emissions allocations for the period 2013-2020.
Jurisdictions:
  • European Union
    • European Court of Justice
READ MORE

INEOS Köln GmbH v Republic of Germany

At issue: INEOS challenged the national legislation, derived from Directive 2003/87/CE, that excluded incompletely oxidised carbon in a liquid state from free emissions allocations.
Jurisdictions:
  • European Union
    • European Court of Justice
READ MORE

Trinseo v. Federal Republic of Germany

At issue: Following the rejection by Germany of Trinseo’s application for free allocation of emission allowances, the ECJ must decide whether the directive n°2003/87/CE, that establishes a system of emission allowances and regulates the free allocation of those allowances, is applicable to the production of polycarbonate operated by Trinseo.
Jurisdictions:
  • European Union
    • European Court of Justice
READ MORE

Poland v. European Parliament, Council of the EU

At issue: Poland unsuccessfully challenged the European Union’s decision to adopt a market stability reserve (which would effectively raise fossil fuel prices) on procedural grounds.
Jurisdictions:
  • European Union
    • European Court of Justice
READ MORE

Do-Hyun Kim et al. v. South Korea

At issue: South Korean youth filed suit against the government alleging that insufficient action on climate change violates their fundamental rights.
Jurisdictions:
  • South Korea
    • Constitutional Court
READ MORE

Greenpeace Poland v. PGE GiEK

At issue: Greenpeace sued utility to compel GHG reductions.
Jurisdictions:
  • Poland
    • Regional Court in Łódź
READ MORE

Smith v. Fronterra Co-Operative Group Limited

At issue: Plaintiff brought tort claims against GHG emitters, seeking to enjoin polluting activities.
Jurisdictions:
  • New Zealand
    • High Court of New Zealand
READ MORE

In the Matter of the Greenhouse Gas Pollution Pricing Act, SC 2018, c. 12

At issue: Whether Canada's carbon pricing act is unconstitutional.
Jurisdictions:
  • Canada
    • Alberta Court of Appeal
READ MORE

Greenpeace et al. v. Austria

At issue: Greenpeace sued to invalidate tax credits on air travel, arguing that GHGs pose a threat to human rights.
Jurisdictions:
  • Austria
    • Constitutional Court
READ MORE

Philippi Horticultural Area Food & Farming Campaign, et al. v. MEC for Local Government, Environmental Affairs and Development Planning: Western Cape, et al.

At issue: Petitioners challenged administrative decision allowing urban development.
Jurisdictions:
  • South Africa
    • High Court
READ MORE

Lho’imggin et al. v. Her Majesty the Queen

At issue: Indigenous groups alleged Canada's climate policy, approval of GHG-emitting projects violate human and constitutional rights.
Jurisdictions:
  • Canada
    • Federal Court
  • Canada
    • Federal Court of Appeal
READ MORE

ClientEarth v. Secretary of State

At issue: Environmental group challenged government's decision to approve natural gas plant.
Jurisdictions:
  • United Kingdom
    • England and Wales
      • Court of Appeal
  • United Kingdom
    • England and Wales
      • High Court of Justice, Queen's Bench Division
READ MORE

Ruling on Modification to Ethanol Fuel Rule

At issue: Whether Mexico's rule increasing the maximum ethanol fuel content is constitutional.
Jurisdictions:
  • Mexico
    • Supreme Court
READ MORE

© 2021 · Sabin Center for Climate Change Law · U.S. Litigation Chart made in collaboration with Arnold & Porter Kaye Scholer LLP

These materials are intended to be a useful resource and may be considered attorney advertising in some jurisdictions. They are for informational purposes only and do not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.