{
  "id": "RS20012",
  "type": "CRS Report",
  "typeId": "REPORTS",
  "number": "RS20012",
  "active": false,
  "source": "EveryCRSReport.com",
  "versions": [
    {
      "source": "EveryCRSReport.com",
      "id": 102414,
      "date": "1999-01-05",
      "retrieved": "2016-05-24T20:47:50.807941",
      "title": "The Future of the Citizen Suit After Steel Co. and Laidlaw",
      "summary": "Two recent court decisions have called into question the viability of environmental citizen suits. \nIn\n Steel Co. , the Supreme Court denied plaintiff standing in a citizen suit where the\ndefendant came into\ncompliance after plaintiff sent its notice of intent to sue, but before it filed the complaint. \nSubsequently ,  the Fourth Circuit in  Laidlaw  invoked mootness doctrine to\nextend  Steel Co.  to where\nthe citizen-suit defendant achieves compliance  after  the complaint is filed, but before\nentry of final\njudgment. To be sure, both suits resulted in compliance. But they also allow defendants to foreclose\ncivil penalties by coming into compliance, eliminating much of the incentive citizen suits create for\nadvance compliance. In addition, the possibility of case dismissal and denial of litigation costs\nwhen the defendant cures its transgression in time may make citizen suits unattractive to the many\ncitizen enforcers who depend on such cost awards. Should Congress find it appropriate to address\nthis situation (the citizen suit concept has its detractors as well as supporters),  Steel Co. \nand  Laidlaw \narguably could be negated by various amendments to current citizen suit provisions.",
      "type": "CRS Report",
      "typeId": "REPORTS",
      "active": false,
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          "encoding": null,
          "url": "http://www.crs.gov/Reports/pdf/RS20012",
          "sha1": "1adea6352fe08cfabb00a4c1c7e4565e3521b8b8",
          "filename": "files/19990105_RS20012_1adea6352fe08cfabb00a4c1c7e4565e3521b8b8.pdf",
          "images": null
        },
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      ],
      "topics": []
    }
  ],
  "topics": [
    "American Law"
  ]
}