Federalism and California's Climate Change Initiatives

Contrary to it being a political issue, climate change is a real problem that is slowly destroying the planet that we call home. Many Americans are doing what they can to combat the effects of climate change, but a large majority still do not see the purpose. However, some states are taking the necessary steps to at least slow down the ramifications. California should have the authority to impose higher fuel standards in their state for the purpose of counteracting the effects of climate change for a multitude of reasons. First and foremost, California reserves eight of the top 10 most polluted cities in the United States (Rice, 2018). The quality of air in California is overwhelmingly contaminated, and one of the main reasons is because of car emissions. The second reason why California believes this law should be enacted is the reduction of the state’s water supply. 2014 and 2015 were two of the hottest years in the state’s recorded history, and the Governor at the time declared a drought emergency (Hanak, E., Mount, J., & Chappelle, C., 2016).

The hypothetical federal law requiring California drivers to meet minimum fuel efficiency standards for vehicles registered in the state is constitutional. The law states that automobiles, not including retail and commercial trucks that fail to meet the minimum fuel efficiency standard of 50 miles per gallon, must pay an annual fee of $200. In this paper, I will argue the constitutionality of California’s actions by using Supreme Court cases to prove my point.

There are certain parts of commerce that can be delegated to the states, as we see in Cooley. V. Board of Wardens of the Port of Philadelphia. Even though this case was rolled out in the 1850s, its conclusion still holds true. A law required ships entering or leaving the Port of Philadelphia to hire a local pilot, and ships that failed this task were to be fined. Colley, a shipowner, refused to do and refused to pay the fine. Justice Curtis delivered the opinion. “The power to regulate commerce embraces a vast field, containing not only many but exceedingly various subjects, quite unlike their nature; some imperatively demanding a single uniform rule, operating equally on the commerce of the United States in every port; and some, like the subject now in question, as imperatively demanding that diversity, which alone can meet the local necessities of navigation (Weaver, 2016).” The conclusion was that Congress’ power was exclusive. A similar ruling could be applied to California in regard to their miles per gallon standard.

On the other hand, there are definitely cases that the Supreme Court has argued that could indicate that Commerce Clause cases relating to federalism might be on a case-by-case basis. Take Southern Pacific Co. v. Arizona, for example. The state of Arizona, similar to California, wanted to penalize those who were imposing health and safety risks on the state’s citizens. The state of Arizona imposed a penalty on railroad companies that were operating trains with 15 or more passenger cars and/or 70 freight cars from Southern Pacific Co. A trial court concluded that the company was not liable because the law itself violated the Commerce Clause, but the Arizona Supreme Court disagreed and reversed the trial court’s opinion.

Eventually, The Supreme Court reversed the Arizona court, stating that: “The unchallenged findings leave no doubt that the Arizona Train Limit Law imposes a serious burden on interstate commerce…if one state may regulate train lengths, so may all the others, and they need not prescribe the same maximum limitation (Weaver, 2016).” The Supreme Court’s main decision in reversing Southern Pacific Co. v. Arizona was that creating new standards for railroads would significantly damage interstate commerce. While this case tried to take on something monumental like railroad transportation, the California law is proposing to create a new standard for automobiles, not including retail and commercial trucks.

Another important case that would uphold California’s proposed law is Garcia v. San Antonio Metro Transit. SAMTA, the number one provider of transportation in the San Antonio area, believed they were exempt from the minimum-wage requirements enacted by the Fair Labor Standards Act. The Court held that SAMTA was subject to the Commerce Clause and that there was little direction on knowing the boundaries of federal and state power. Justice Blackmun delivered the opinion. “The essence of our federal system is that within the realm of authority left open to them under the Constitution, the States must be equally free to engage in any activity that their citizens choose for the commonwealth, no matter how unorthodox or unnecessary anyone else deems state involvement to be (Weaver, 2016).” Justice Blackmun wrote that it is a tricky line to walk in regard to federal and state power and that states should enforce what they ultimately believe is necessary. Therefore, this belief can be applied to the state of California since they believe cutting down on car emissions is necessary for their state’s well-being and future.

While it is impossible to predict the unknown, I believe that the Supreme Court would rule in favor of California’s climate change initiatives, similar to what we saw in Cooley. V. Board of Wardens of the Port of Philadelphia. Occupy the field means that if there is a subject area of law, you look at federal law and see if there is any wiggle room. If so, then the federal law controlling any state law is void. This case proved that there was indeed wiggle room in regard to federal law. Even though there were cases discussed in this paper that ultimately didn’t win, their dissents gave context to the proposed law.

In Southern Pacific Co. v. Arizona, we saw that those trying to create new standards for railroads were actually doing more harm than good. We learned from this case how, sometimes, there was just too much that could potentially damage interstate commerce and how a case might be determined differently if there were restrictions, such as the California law, which only wants to include automobiles and not include retail and commercial trucks. Finally, in Garcia v. San Antonio Metro Transit, we saw from Justice Blackmun’s dissent that “states must be equally free to engage in any activity that their citizens choose for the commonwealth.” California could interpret this ruling in its favor. Ultimately, California’s actions in relation to federalism are constitutional.

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