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California's Mandatory Climate Reporting Stayed Pending Appeal

Today, the Ninth Circuit Court of Appeals issued an injunction pending appeal of one of California's two mandatory climate disclosure laws--S.B. 261, which mandates the disclosure of climate-related financial risk, and which...more

Ninth Circuit Will Not Enjoin California Climate Disclosure Regulations Before They Enter Into Force

On October 29, 2025, the Ninth Circuit scheduled oral argument on the Chamber of Commerce's appeal of the district court decision denying the sought injunction to block California's mandatory climate disclosure laws--and the...more

California's Mandatory Climate Disclosure Regulations Challenged by New Lawsuit

On October 24, 2025, a significant new lawsuit challenging California's mandatory climate disclosure regulations was filed in federal district court (E.D. Cal.) by ExxonMobil...more

Sustainable Energy & Infrastructure Litigation Updates — November 2025

On October 9, 2025, SEC Chairman Atkins delivered a speech in which he inveighed against “shareholder proposals focused on environmental and social issues.” According to Chairman Atkins, “these proposals consume a significant...more

SEC To Discourage ESG Shareholder Proposals

On October 9, 2025, SEC Chairman Atkins delivered a speech in which he inveighed against “shareholder proposals focused on environmental and social issues.” According to Chairman Atkins, “these proposals consume a...more

Competitor Accuses Rival of "Greenwashing" When Advertising Its Products

Last month, an earplug maker sued a rival in federal district court in California, alleging that the competitor had engaged “[i]n a calculated ‘greenwashing’ scheme to capture market share from competitors . . . by falsely...more

Court Awards Zero Damages for Breach of Fiduciary Duty Stemming from Pension Plan's ESG-Focused Investing

Following a bench trial, Judge O'Connor (N.D. Tex.) held that there had been a breach of the fiduciary duty of loyalty based upon a 401(k) retirement plan's investments, which reflected ESG interests rather than strictly...more

Sustainable Energy & Infrastructure Litigation Updates — October 2025

On September 12, 2025, the Eighth Circuit Court of Appeals ordered that the legal challenge to the Biden administration’s climate disclosure regulation be “held in abeyance” until the “Securities and Exchange Commission...more

California Identifies 4,100+ Companies Subject to Mandatory Climate Disclosures

On September 24, 2025, the California Air Resources Board (CARB) — the state regulator responsible for implementing California’s new mandatory climate disclosure regulations — released a preliminary list of about 4,100...more

CFTC Withdraws Guidance on Carbon Credits

On September 10, 2025, the Commodities Futures Trading Commission withdrew guidance--promulgated by the Biden Administration in September 2024--concerning the market for voluntary carbon credits. Specifically, the CFTC...more

Eighth Circuit Orders SEC to Either Defend Climate Disclosure Regulation or Write New Rules

On Friday, the Eighth Circuit Court of Appeals ordered that the legal challenge to the Biden Administration's climate disclosure regulation be “held in abeyance” until the “Securities and Exchange Commission reconsiders the...more

California Issues Further Guidance For Climate Disclosures

Last week, on September 2, 2025, the California Air Resources Board announced that it had “released draft guidance to assist reporting entities in complying with the Climate Related Financial Risk Disclosure Program.” This...more

Sustainable Energy & Infrastructure Litigation Updates — September 2025

On August 1, 2025, a federal district court judge rejected the attempt by three major asset managers to dismiss an antitrust complaint filed by a coalition of 11 Republican state attorneys general (and subsequently receiving...more

Denmark's Largest Bank Maintains Climate Commitment and Divests from Over 1700 Fossil Fuel Companies

Last week, Danske Bank--Denmark's largest bank--announced that it would no longer invest in over 1700 fossil fuel companies due to their failure to adequately prepare for climate change. Specifically, their “investment...more

The Trump Administration Dismantles California's "Clean Truck Partnership" Through the Use of Antitrust Law

On August 12, 2025, the Federal Trade Commission announced that it had “closed its investigation into whether several truck and engine manufacturers and their trade association violated the antitrust laws by entering the...more

Federal District Court Rejects Challenge to California's Climate Disclosure Law

On August 13, 2025, the challenge to the State of California's mandatory climate disclosure regulations was resoundingly rejected by Judge Wright (C.D. Cal.). The preliminary injunction-- sought by the U.S. Chamber of...more

Florida Attorney-General Bans Outside Counsel with DEI & ESG Policies

The State of Florida's Attorney-General has increased the scope of his offensive against DEI and ESG initiatives. Not only has the Florida AG announced an investigation into climate non-profits concerning environmental...more

Trump Executive Order Attacks "De-banking" Practices

On August 7, 2025, President Trump issued an executive order targeting the practice of de-banking--as described in the executive order, actions to “restrict law-abiding individuals' and business' access to financial services...more

Climate Tort Lawsuit in South Carolina Dismissed by State Court

On August 6, 2025, a state court judge in South Carolina dismissed the climate change tort lawsuit filed by the City of Charleston against a number of major fossil fuel companies. (This lawsuit was one of approximately three...more

Red State AGs' ESG Antitrust Complaint Against Asset Managers Survives Motion to Dismiss

Last fall, a coalition of eleven Republication attorneys-general filed an antitrust complaint against three major asset managers, alleging that the asset managers' adherence to climate-friendly principles--which discourage...more

European Union Proposes Reduction in Climate Reporting Obligations

Last week, significant revisions were proposed to the European Union's ESG reporting rules, which reflect a major simplification and reduction in reporting obligations. Among other things, the revisions would reduce...more

Sustainable Energy & Infrastructure Litigation Updates — August 2025

There was a noteworthy development in the ongoing legal challenge to the SEC’s mandatory climate disclosure law (dating from the Biden administration), which is currently pending in the Eighth Circuit. Following the decision...more

Florida AG Announces Investigation into Climate Nonprofits for Alleged Violations of Consumer Protection and Antitrust Laws Based...

3 On July 28, 2025, the Republican Attorney-General of Florida announced that his office had “issued subpoenas to investigate whether the CDP (formerly the Climate Disclosure Project) and the Science Based Targets Initiative...more

SEC Refuses to Answer Whether It Will Enforce Climate Disclosure Law If Upheld by Courts

On July 23, 2025, there was a notable development in the legal proceeding (currently pending in the Eighth Circuit) challenging the validity of the SEC's mandatory climate disclosure law. By way of background, in April...more

Missouri AG Launches Investigation of Proxy Advisory Firms Related to Alleged ESG-Focused Recommendations

The Missouri Attorney-General, Republican Andrew Bailey, recently announced an investigation into the two principal proxy advisory firms for potential violations of Missouri law “related to their promotion of radical...more

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