Federal Court Dismisses Government's Attempt to Block Hawaii's Climate Change Lawsuit
On April 15, 2026, the U.S. District Court for the District of Hawaii dismissed with prejudice the federal government's lawsuit seeking to block the state of Hawaii from pursuing climate change-related tort claims against oil and gas companies in state court. The ruling is a significant development in the ongoing legal battles between the federal government and states asserting claims against energy companies for alleged climate impacts.
On April 30, 2025, the U.S. Department of Justice ("DOJ") filed a complaint for declaratory and injunctive relief against the state of Hawaii, Governor Joshua Booth Green, and Attorney General Anne E. Lopez. The complaint was filed two days after Hawaii announced its intention to sue energy companies in state court, and one day before the state actually filed its lawsuit. The government contended that Hawaii's lawsuit would raise energy costs nationwide, undermine federal regulatory authority, and interfere with U.S. foreign policy on climate change.
The District Court granted Hawaii's motion for judgment on the pleadings, finding that the United States failed to establish Article III standing on all three required elements: injury-in-fact, causation, and redressability.
First, the court held that the government failed to allege a concrete injury. The court found that the complaint's allegations of harm to federal sovereignty, energy policy, and commerce were merely "legal conclusions" not entitled to a presumption of truth. Second, the court found the government's theory of causation was fatally speculative, requiring multiple layers of prediction: forecasting the nature of Hawaii's claims, predicting Hawaii's success in litigation, guessing how energy companies would react, and hypothesizing that those reactions would ultimately harm federal interests. In the court's words, "[p]otential litigation between the state of Hawaii and private fossil fuel entities would not require the United States to do anything or to refrain from doing anything." Third, the court concluded that the requested relief was not redressable, emphasizing the longstanding principle that federal and state courts do "not interfere with or try to restrain each other's proceedings" (quoting Donovan v. City of Dallas, 377 U.S. 408, 412 (1964)).
Notably, the court also stated that the government's characterization of Hawaii's legal theories was incorrect. While the federal complaint asserted that Hawaii would attempt to regulate greenhouse gas emissions, the court stated that the tort claims centered on deceptive marketing practices by energy companies. The court dismissed the case with prejudice after the government declined an opportunity to amend its complaint.
The propriety of states seeking to pursue climate cases against energy companies will continue to be vigorously litigated. After the Hawaii court's ruling, the DOJ indicated it is "exploring all options," suggesting a potential appeal to the Ninth Circuit. The Hawaii decision follows a similar outcome in United States v. Michigan, where a federal court likewise found the government lacked standing to block a state from suing energy companies. But the DOJ filed another lawsuit against Minnesota on May 4, 2026, alleging the state's lawsuit against oil and gas companies intrudes on EPA's authority to regulate greenhouse gases and the president's authority to enforce foreign policy. And the Maryland Supreme Court recently held that the climate tort claims there could not proceed because they were preempted by federal law.
