United States v. Hawaii
ELR Citation: 56 ELR 20053 No(s). 25-00179 HG-WRP (D. Haw. Apr 15, 2026) (Gillmor, J.)
A district court granted the state of Hawaii's motion for judgment on the pleadings in a lawsuit brought by the federal government seeking to prevent the state from suing private fossil fuel entities in state court. The state moved to dismiss, arguing the government lacked standing to request a federal court to issue an order that would enjoin a state from suing private entities in its own courts. The court found the government's attempt to predict the outcome of a yet-to-be-filed lawsuit and how it could possibly injure the government in the future was not a concrete injury-in-fact. It further found no predictable causal chain of injury directly to the government and that potential litigation between Hawaii and private entities would not require the federal government to do or to refrain from doing anything. It dismissed the suit.