County of San Mateo v. Peabody Energy Corporation, No. 18-3242 (8th Cir. 2020)
Annotate this Case
After Peabody was reorganized, three California municipalities filed suit against Peabody and more than thirty other energy companies for their alleged contributions to global warming. The bankruptcy court enjoined the municipalities from pursuing their claims against Peabody. The district court affirmed.
The Eighth Circuit affirmed and held that all the claims in the complaint are directed at Peabody's pre-bankruptcy conduct and are barred. The court rejected the municipalities' claim that the Environmental Law provision exempted their claims from discharge. The court held that their common-law claims against Peabody are "state or local equivalents" of "statutes, regulations and ordinances concerning pollution," holding that the bankruptcy court reasonably concluded that when the definition of Environmental Law mentioned state or local equivalents, it was talking about equivalents to the ten federal statutes listed, not equivalents to statutes, regulations and ordinances concerning pollution. Furthermore, the municipalities have not demonstrated that their common law claims are equivalent to the listed federal statutes. The court also rejected a second provision that the municipalities rely on for the survival of their claims, which exempts from discharge a governmental claim brought "under any . . . applicable police or regulatory law." The court disagreed with the municipalities' contention that, since their representative public-nuisance claim entitles them only to the equitable remedy of abatement, it is not dischargeable in bankruptcy.
Court Description: [Arnold, Author, with Gruender and Shepherd, Circuit Judges] Civil case - Bankruptcy. The environmental law carve-out in the discharge from governmental claims did not except plaintiffs' common law claims; nor were their claims excepted from discharge by a provision exempting from discharge a governmental claims brought "under ... any applicable police or regulatory law;" the claim that because the plaintiffs' representative public-nuisance claim entitles them only to the equitable relief of abatement it is not dischargeable in bankruptcy was properly rejected; all the municipalities' claims concern Peabody's pre-bankruptcy conduct and are barred.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.