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Case 3:17-Md-02777-EMC Document 542 Filed 03/29/19 Page 1 of 25 Case 3:17-md-02777-EMC Document 542 Filed 03/29/19 Page 1 of 25 1 LEIGH P. RENDÉ (PA Bar No. 203452) 2 JOSEPH W.C. WARREN (DC Bar No. 452913) UNITED STATES DEPARTMENT OF JUSTICE 3 Environment and Natural Resources Division 4 Environmental Enforcement Section 5 P.O. Box 7611, Ben Franklin Station Washington, DC 20044-7611 6 Telephone: (202) 514-1461 7 Email: [email protected] 8 Email: [email protected] 9 Counsel for the United States 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 IN RE: CHRYSLER-DODGE-JEEP Case No. 3:17-md-02777-EMC 15 ECODIESEL MARKETING, SALES 16 PRACTICES, AND PRODUCTS UNITED STATES’ NOTICE OF MOTION, 17 LIABILITY LITIGATION MOTION, AND MEMORANDUM IN SUPPORT OF ENTRY OF CONSENT 18 DECREE 19 20 Hearing: May 3, 2019 Time: 10:00 a.m. 21 Ct. Rm.: 5, 17th Floor 22 23 The Honorable Edward M. Chen 24 25 26 27 28 Case 3:17-md-02777-EMC Document 542 Filed 03/29/19 Page 2 of 25 1 UNITED STATES, 2 Plaintiff, 3 4 v. 3:17-cv-3446-EMC 5 FCA US LLC, 6 FIAT CHRYSLER AUTOMOBILES 7 N.V., V.M. MOTORI S.P.A., and 8 V.M. NORTH AMERICA, INC., 9 Defendants. 10 11 PEOPLE OF THE STATE OF CALIFORNIA, 12 13 Plaintiff, 3:19-cv-00151-EMC 14 v. 15 16 FIAT CHRYSLER AUTOMOBILES 17 N.V., FCA US LLC, V.M. MOTORI S.P.A., and 18 V.M. NORTH AMERICA, INC., 19 20 Defendants. 21 22 23 24 25 26 27 28 U.S. MOTION FOR ENTRY OF CONSENT DECREE 3:17-md-2777-EMC - ii Case 3:17-md-02777-EMC Document 542 Filed 03/29/19 Page 3 of 25 1 Table of Contents 2 NOTICE OF MOTION AND MOTION ........................................................................................ 1 3 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT ........................................ 2 4 I. Introduction ......................................................................................................................... 2 5 II. Background ......................................................................................................................... 4 6 A. Summary of Allegations in the Complaint ..................................................................... 4 7 B. Summary of Terms of the Consent Decree..................................................................... 5 8 C. Relationship Between This Consent Decree and the Class Action Settlement .............. 9 9 III. Legal Standard .................................................................................................................... 9 10 IV. The Public Comment Process ........................................................................................... 10 11 V. The Settlement is Fair, Reasonable, and Consistent with the Objectives of 12 the Clean Air Act and Should Be Entered by the Court. .................................................. 11 13 A. The Settlement is Fair. .................................................................................................. 11 14 B. The Settlement is Reasonable and Advances the Purposes of the Clean Air Act. ....... 13 15 VI. None of the Comments Received During the Period for Public Comment 16 Warrant Disapproval of the Proposed Consent Decree. ................................................... 16 17 A. Comments by Mr. Richard Angell ................................................................................ 16 18 B. Comments by Certain Tribal Committees .................................................................... 17 19 VII. Conclusion ........................................................................................................................ 18 20 21 22 23 24 25 26 27 28 U.S. MOTION FOR ENTRY OF CONSENT DECREE 3:17-md-2777-EMC - iii Case 3:17-md-02777-EMC Document 542 Filed 03/29/19 Page 4 of 25 1 Table of Exhibits 2 1. Consent Decree 3 2. Comments Received by Department of Justice 4 5 Table of Authorities 6 Cases 7 Citizens for Better Env’t v. Gorsuch, 718 F.2d 1117 (D.C. Cir. 1983) ........................................ 10 8 Heckler v. Chaney, 470 U.S. 821, 831 (1985) .............................................................................. 17 9 In re Volkswagen “Clean Diesel” Mktg., Sales Practices, & Prods. Liab. Litig. 10 No. 15-md-2672 CRB (N.D. Cal. Oct. 25, 2016) ..................................................................... 17 11 Officers for Justice v. Civil Serv. Comm’n, 688 F.2d 615 (9th Cir. 1982) ................................... 10 12 SEC v. Randolph, 736 F.2d 525, 529 (9th Cir. 1984) ................................................................... 10 13 Speed Shore Corp. v. Denda, 605 F.2d 469 (9th Cir. 1979) ......................................................... 10 14 United States v. Azko Coatings of Am., Inc., 949 F.2d 1409 (6th Cir. 1991) ............................... 10 15 United States v. Cannons Eng’g Corp., 899 F.2d 79, 84 (1st Cir. 1990) ....... 10, 11, 12, 13, 14, 18 16 United States v. Chevron U.S.A. Inc., 380 F. Supp. 2d 1104, 1111 17 (N.D. Cal. 2005)................................................................................................ 10, 11, 12, 13, 18 18 United States v. City of Miami, Fla., 664 F.2d 435, 441 (5th Cir. 1981) ..................................... 15 19 United States v. Coeur d’Alenes Co., 767 F.3d 873, 877 (9th Cir. 2014)..................................... 11 20 United States v. Colorado, 937 F.2d 505 (10th Cir. 1991) ........................................................... 12 21 United States v. McInnes, 556 F.2d 436 (9th Cir. 1977) .............................................................. 10 22 United States v. Montrose Chem. Corp., 50 F.3d 741, 743 (9th Cir. 1995) ........................... 10, 15 23 United States v. Oregon, 913 F.2d 576, 580 (9th Cir. 1990) ........................................ 9, 12, 13, 18 24 United States v. Pacific Gas & Electric, 776 F. Supp. 2d 1007, 1024-25 25 (N.D. Cal. 2011)........................................................................................................................ 13 26 United States v. Wallace, 893 F. Supp. 627, 632 (N.D. Tex. 1995) ............................................. 12 27 28 U.S. MOTION FOR ENTRY OF CONSENT DECREE 3:17-md-2777-EMC - iv Case 3:17-md-02777-EMC Document 542 Filed 03/29/19 Page 5 of 25 1 Statutes 2 42 U.S.C. § 7401(b)(1) ................................................................................................................. 15 3 42 U.S.C. §§ 7521 through 7590 ................................................................................................ 1, 4 4 42 U.S.C. § 7522 ............................................................................................................................. 5 5 42 U.S.C. § 7522(a)(1) .................................................................................................................... 5 6 42 U.S.C. § 7522(a)(2)(A) .............................................................................................................. 5 7 42 U.S.C. § 7522(a)(3)(A) .............................................................................................................. 5 8 42 U.S.C. § 7522(a)(3)(B) .............................................................................................................. 5 9 42 U.S.C. §§ 9601-9675 ............................................................................................................... 14 10 Regulations 11 28 C.F.R. § 50.7 ............................................................................................................................ 10 12 40 C.F.R. § 86.1843-01 ................................................................................................................... 4 13 40 C.F.R. § 86.1844-01(d) .............................................................................................................. 4 14 40 C.F.R. § 86.1848-10(c)(6).......................................................................................................... 4 15 84 Fed. Reg. 1230 ..................................................................................................................... 1, 11 16 17 18 19 20 21 22 23 24 25 26 27 28 U.S. MOTION FOR ENTRY OF CONSENT DECREE 3:17-md-2777-EMC - v Case 3:17-md-02777-EMC Document 542 Filed 03/29/19 Page 6 of 25 1 NOTICE OF MOTION AND MOTION 2 TO ALL PARTIES AND COUNSEL OF RECORD: 3 PLEASE TAKE NOTICE that on May 3, 2019, at 10:00 a.m., or at such other date as 4 may be agreed upon, in Courtroom 5 (17th floor) of the United States District Court for the 5 Northern District of California, located at 450 Golden Gate Avenue, San Francisco, California, 6 Plaintiff the United States of America (“United States”) will and hereby does move this Court to 7 enter, as a final judgment in this matter, the Consent Decree submitted to this Court as a 8 Proposed Order and attached to this Motion as Exhibit 1 (“Consent Decree” or “Decree”).1 9 The Consent Decree, which was lodged with this Court on January 10, 2019, resolves 10 violations of Title II of the Clean Air Act (Emissions Standards for Moving Sources), 42 U.S.C. 11 §§ 7521 through 7590, as alleged in the United States’ complaint (“Complaint”), relating to 12 certain diesel vehicles manufactured by FCA US LLC, V.M. Motori S.P.A., V.M. North 13 America, Inc., and Fiat Chrysler Automobiles N.V. (collectively, “Defendants”). The Consent 14 Decree also partially resolves the violations of law alleged in California’s complaint against the 15 Defendants relating to the same vehicles. As set forth below in the Memorandum in Support of 16 this Motion, the Court
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