Cause of Action Rhode Island Statute Tort 
ClimateChange-ClimateLaw
NOVEMBER 16, 2020
The First Circuit—like the Fourth, Ninth, and Tenth Circuits in other climate change cases—concluded that the scope of its appellate review was limited to whether the defendants properly removed the case under the federal-officer removal statute. State court proceedings in Rhode Island’s case were put on hold in August pending the U.S.
ClimateChange-ClimateLaw
JULY 2, 2021
The Court held that the provision used “extension” in its “temporal sense,” but that the statute did not impose a “continuity requirement” and instead allowed small refineries to apply for hardship extensions “at any time.” Living Rivers v. Hoffman , No. 4:19-cv-00057 (D. Utah June 21, 2021). In re Enbridge Energy, LP , Nos.
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