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Keywords

lawsuitplaintiffjurisdictionappealsummary judgmentfiduciarytrustfiduciary duty
lawsuitplaintiffappealfiduciarytrustfiduciary duty

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Chernaik v. Brown, 367 Or. 143, 475 P.3d 68

Facts

The plaintiffs, two young Oregonians and their guardians, filed a lawsuit against the Governor and the State of Oregon, claiming that the state had a fiduciary duty under the public trust doctrine to protect natural resources from the impacts of climate change and greenhouse gas emissions. They sought declaratory relief to establish that the atmosphere and various natural resources were public trust resources and that the state had failed to uphold its obligations to protect them. The Circuit Court initially dismissed the case for lack of jurisdiction, but the Court of Appeals reversed this decision, leading to further proceedings in the Circuit Court where the state was granted summary judgment.

The plaintiffs, two young Oregonians and their guardians, filed a lawsuit against the Governor and the State of Oregon, claiming that the state had a fiduciary duty under the public trust doctrine to protect natural resources from the impacts of climate change and greenhouse gas emissions.

Issue

Does the public trust doctrine extend to the atmosphere and impose fiduciary duties on the state to protect natural resources from the impacts of climate change?

Does the public trust doctrine extend to the atmosphere and impose fiduciary duties on the state to protect natural resources from the impacts of climate change?

Rule

The public trust doctrine applies to navigable waters and the lands underlying those waters, but does not extend to the atmosphere, fish, wildlife, or impose fiduciary duties akin to those of private trustees.

The public trust doctrine applies to navigable waters and the lands underlying those waters, but does not extend to the atmosphere, fish, wildlife, or impose fiduciary duties akin to those of private trustees.

Analysis

The court analyzed the scope of the public trust doctrine, determining that it currently encompasses only navigable waters and the submerged lands beneath them. The court rejected the plaintiffs' argument for an expanded interpretation that would include the atmosphere and other natural resources, stating that the public trust doctrine does not impose fiduciary obligations on the state similar to those owed by private trustees. The court emphasized that the doctrine serves to restrain state action regarding public trust resources rather than impose affirmative duties to protect them from climate change.

The court analyzed the scope of the public trust doctrine, determining that it currently encompasses only navigable waters and the submerged lands beneath them. The court rejected the plaintiffs' argument for an expanded interpretation that would include the atmosphere and other natural resources, stating that the public trust doctrine does not impose fiduciary obligations on the state similar to those owed by private trustees.

Conclusion

The court affirmed the decision of the Court of Appeals, concluding that the public trust doctrine does not extend to the atmosphere or impose fiduciary duties on the state. The case was remanded for a judgment consistent with this opinion.

The court affirmed the decision of the Court of Appeals, concluding that the public trust doctrine does not extend to the atmosphere or impose fiduciary duties on the state. The case was remanded for a judgment consistent with this opinion.

Who won?

The State of Oregon prevailed in the case, as the court upheld the conclusion that the public trust doctrine does not extend to the atmosphere or impose fiduciary duties on the state.

The State of Oregon prevailed in the case, as the court upheld the conclusion that the public trust doctrine does not extend to the atmosphere or impose fiduciary duties on the state.

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