STATE CLIMATE SUPERFUNDS

STATE CLIMATE SUPERFUNDS

The harmful effects of climate change have already arrived in cities and states across America, with disasters increasing markedly in recent years along with more gradual environmental changes like sea-level rise and drought. To protect populations and natural resources, significant funding will be necessary for preventative measures as well as disaster response.

At present, it is states and ordinary taxpayers who must shoulder the enormous costs and planning for climate adaptation. A number of state legislators, however, have recently proposed enacting new laws that would require the companies who have most profited from fossil fuel usage to assist in funding climate adaptation projects. Based on prior liability regimes to deal with hazardous waste harms, these “state climate superfunds” aim to address the unfair distribution of climate adaptation costs and provide an essential complement to regulation of future greenhouse gas emissions.

Drawing on historical, economic, and political science literature, this Article examines these novel proposals and the potential constitutional issues with states passing such laws. It argues that the local nature of climate change harms, the historic role states have played in protecting the environment, and the benefits from decentralized policy experimentation support state leadership on climate superfunds. While certain constitutional provisions and doctrines could limit state authority to draft these laws in particular ways, the Article describes how states can design climate superfunds to conform with prior legal precedents and reasonably balance the competing values at stake as we adapt to a warmer world.

The full text of this Article can be found by clicking the PDF link to the left.

Introduction

On a summer day in July 2023, the skies over Vermont turned apocalyptic. A massive thunderstorm dumped two months of rainfall over the state in about twenty four hours, leading to flash floods that washed away roads, bridges, and homes. 1 Lyric Li, Brady Dennis, Justine McDaniel, Anumita Kaur & Susan Levine, Northeast Storms Dump Over 2 Months’ Worth of Rain on Vermont: Live Weather Updates, Wash. Post (July 11, 2023), https://‌www.washingtonpost.com/weather/‌2023/
07/11/vermont-flooding-new-york-northeast-rain/ (on file with the Columbia Law Review).
The capital city’s water system failed, 2 Id. thousands of people lost their homes and businesses, 3 Justine McDaniel & Joanna Slater, More Than 100 Rescued in Vermont Floods as Search Efforts Continue, Wash. Post (July 11, 2023), https://www.washingtonpost.com/‌climate-environment/2023/07/11/vermont-flood-rescues-officials-brace-rain/ (on file with the Columbia Law Review). hundreds of citizens required rescue, 4 Peter Banacos, The Great Vermont Flood of 10–11 July 2023: Preliminary Meteorological Summary, Nat’l Weather Serv. (Aug. 5, 2023), https://www.weather.gov/btv/The-Great-Vermont-Flood-of-10-11-July-2023-Preliminary-Meteorological-Summary [https://perma.cc/4BMD-MTYV]. and the state narrowly avoided a dam breach that would have closed multiple evacuation routes and threatened severe damage and loss of life. 5 See Chloe Mayer, Vermont Flood Disaster Fears as Officials Warn Wrightsville Dam at Capacity, Newsweek (July 11, 2023), https://www.newsweek.com/ vermont-floods-wrightsville-dam-warning-capacity-1812160 (on file with the Columbia Law Review). As it was, the recovery process took many months and cost hundreds of millions of dollars, with devastating effects on families and businesses. 6 Vermont Public Specials, Montpelier Businesses Face Challenges One Year After Flood (aired July 9, 2024), https://www.vermontpublic.org/ shows/vermont-public-television-specials/episodes/montpelier-businesses-face-challenges-one-year-after-flood-cf9xvk (on file with the Columbia Law Review) (describing about 140 small businesses in Vermont’s capital sustaining more than $20 million in damages from the flood). One woman and her two children lived without walls or floors for months in the aftermath of the flood; despite spending $40,000 from her savings to try to rebuild their farmhouse, she and her children feared they could not salvage the property and would lose their home. 7 Lisa Rathke, 2 Vermont Communities Devastated by Summer Flooding Seek $3.5M to Elevate Homes for Victims, Associated Press (Mar. 20, 2024), https://www.wbur.org/news/2024/ 03/20/vermont-flooding-housing-crisis-funding [https://perma.cc/L3YN-BU5B]. While the federal government provided a considerable amount of funding to assist with the recovery, Vermont was on the hook for $153 million—an enormous sum for one of the smallest states in the nation to rebuild from a single storm. 8 See Rising Danger: The Cost of Flooding, St. Vt., https://floodready.‌
vermont.gov/flood_costs (last visited Jan. 19, 2026) [https://‌perma.cc/D3E8-D44P].
In each of the following two years, on almost exactly the same day, Vermont experienced another episode of catastrophic flash flooding. 9 Pat Bradley, Vermont Governor Recalls Two Flood Events Exactly One Year Apart and Tours Continuing Recovery Work, WAMC Ne. Pub. Radio (July 10, 2025), https://www.wamc.org/news/2025-07-10/vermont-governor-recalls-two-flood-events-exactly-one-year-apart-and-tours-continuing-recovery-work [https://perma.cc/P7W3-RW5E]; Associated Press, Vermont Communities Face Third Consecutive Summer of Severe Flooding, DamageExtensive, Fox 11 News (July 11, 2025), https://fox11online.com/news/ nation-world/vermont-communities-face-third-consecutive-summer-of-severe-flooding-damage-extensive-burlington-extreme-weather-rain-waterways-national-weather-service-climate-change (on file with the Columbia Law Review). The total amount of damage from these extreme weather events has now exceeded $1 billion. 10 See Bradley, supra note 9.

The effects of climate change no longer await Americans in a future world that we might still avoid. 11 See Intergovernmental Panel on Climate Change, Climate Change 2023 Synthesis Report: Summary for Policymakers 23 (2023), https://www.ipcc.ch/report/ar6/ syr/downloads/report/IPCC_AR6 _SYR_SPM.pdf [https://perma.cc/8QDP-W7DK] (“Over­shooting 1.5°C will result in irreversible adverse impacts on certain ecosystems with low resilience, such as polar, mountain, and coastal ecosystems, impacted by ice-sheet melt, glacier melt, or by accelerating and higher committed sea level rise.”); Press Release, World Meteorological Org., Global Climate Predictions Show Temperatures Expected to Remain at or Near Record Levels in Coming 5 Years (May 26, 2025), https://wmo.int/news/media-centre/global-climate-predictions-show-temperatures-expected-remain-or-near-record-levels-coming-5-years [https://perma.cc/K8SQ-K3ZF] (explaining that the five-year global average warming between 2025 and 2029 is likely to exceed 1.5 degrees Celsius). They have arrived in cities and states across the country just like Vermont. 12 Chelsea Harvey, ‘Biggest, Baddest’ Rainfall Events Are Getting Worse, E&E News (July 25, 2025), https://subscriber.politicopro.com/ article/eenews/2025/07/25/biggest-baddest-rainfall-events-are-getting-worse-00471671 [https://perma.cc/5GT6-XB9T] (“[H]eavy precipitation events are among the clearest symptoms of climate change . . . . Copious studies warn that they’re already happening more often and becoming more intense, and they’ll continue to worsen as global temperatures rise.”). Since the 1970s, U.S. temperatures have risen about two degrees Fahrenheit, resulting in more frequent episodes of severe precipitation, poorer air quality, and greater risk of insect-borne diseases. 13 Earth Day: Fastest-Warming Cities and Record Clean Investment, Climate Cent. (Apr. 17, 2024), https://www.climatecentral.org/ climate-matters/earth-day-fastest-warming-cities [https://perma.cc/SA43-BVZR]. Warming in the United States is happening about 60% faster than the rest of the globe, leaving the country more susceptible than other parts of the world to particular climate effects. 14 Wenying Su et al., Climate Trends, in U.S. Glob. Change Rsch. Program, Fifth National Climate Assessment 2-2, 2-4 (Allison R. Crimmins, Christopher W. Avery, David R. Easterling, Kenneth E. Kunkel, Brooke C. Stewart & Thomas K. Maycock eds., 2023), https://toolkit.climate.gov/sites/ default/files/2025-07/NCA5_2023_FullReport.pdf (on file with the Columbia Law Review); see also Sachi Kitajima Mulkey, Claire Brown & Mira Rojanasakul, The World Is Warming Up. And It’s Happening Faster., N.Y. Times (June 26, 2025), https://www.nytimes.com/2025/06/ 26/climate/climate-heat-intensity.html (on file with the Columbia Law Review) (describing how increasing temperatures have corre­sponded with even “larger increase[s] in atmospheric extremes, like extreme downpours and severe droughts and wildfires” (internal quotation marks omitted) (quoting Daniel Swain, Climate Scientist, Univ. of Ca.)). Even under the most ambitious plans for rapidly reducing greenhouse gas emissions, we cannot avoid some harms from climate change because of warming from past emissions. 15 See Naiming Yuan, Christian L.E. Franzke, Feilin Xiong, Zuntao Fu & Wenjie Dong, The Impact of Long-Term Memory on the Climate Response to Greenhouse Gas Emissions, Clim. & Atmos. Sci., Sep. 12, 2022, at 1 (“[E]ven if no more carbon dioxide were emitted to the atmosphere now, or more realistically speaking, if the target of carbon neutralization were achieved, the global temperature may still rise for decades to reach an equilibrium state.”); see also Intergovernmental Panel on Climate Change, Special Report: Global Warming of 1.5 °C, at 51 (2022), https://www.ipcc.ch/site/assets/uploads/‌sites/2/2022/06/SR15_Full_Report _HR.pdf, [https://perma.cc/HE93-XZ43] (explaining that, while it may still be possible to avoid increasing global average temperatures above 1.5 degrees Celsius, we have already exceed­ed 1 degree warming, and past emissions will likely lead to an additional rise in tempera­tures and environmental effects like sea-level rise). The reason for this delay is thermal inertia in the planet’s oceans. See Jesse F. Abrams et al., Committed Global Warming Risks Triggering Multiple Climate Tipping Points, Earth’s Future, Nov. 2023, at 1, 2. Scientists first identified the possibility of such a delay in the environmental effects of greenhouse gas emissions in the 1980s, should fossil fuel use continue. These scientists included those working for the oil industry. See James E. Hansen et al., Global Warming in the Pipeline, Oxford Open Climate Change, Nov. 2, 2023, at 1, 2 (“[T]he danger caused by climate’s delayed response and the need for anticipatory action to alter the course of fossil fuel development was apparent to scientists and the fossil fuel industry 40 years ago.”). These effects include more extreme weather events, sea-level rise, coastal erosion, and floods. 16 While there is some uncertainty regarding the severity of certain climate harms, such as the exact amount of warming that will trigger tipping points like cessation of ocean circulation patterns, at present, there is well-accepted scientific research indicating that we have surpassed the amount of warming that will cause dramatic changes to the planet. For example, recent studies have shown that the melting of the West Antarctic ice sheet is all but certain, which will cause significant sea-level rise and damage to coastal cities. See Kaitlin A. Naughten, Paul R. Holland & Jan De Rydt, Unavoidable Future In­crease in West Antarctic Ice-Shelf Melting over the Twenty-First Century, 13 Nat. Clim. Chang. 1222, 1223 (2023). Researchers have also documented how ocean warming has intensified recent hurricanes. See, e.g., Daniel M. Gilford, Joseph Giguere & Andrew J. Pershing, Human-Caused Ocean Warming Has Intensified Recent Hurricanes, Env’t Rsch., Nov. 20, 2024, at 1, 16. On the challenges with predicting tipping points like chang­es to ocean circulation patterns, see Anand Gnanadesikan et al., Tipping Points in Overturning Circulation Mediated by Ocean Mixing and the Configuration and Magnitude of the Hydrological Cycle: A Simple Model, 54 J. Phys. Oceanogr. 1389, 1390 (2024).

The reelection of President Donald Trump to a second term has only increased the need for Americans to adapt to climate change. The Trump Administration is ending even modest steps to limit greenhouse gas emissions domestically, rolling back climate regulations for power plants and motor vehicles. 17 See Rescission of the Greenhouse Gas Endangerment Finding and Motor Vehicle Greenhouse Gas Emission Standards Under the Clean Air Act, 91 Fed. Reg. 7686 (Feb. 18, 2026) (to be codified at 40 C.F.R. pts. 85, 86, 600, 1036, 1037, 1039); Sean Reilly, Trump Admin Advances Climate Reg Overhaul, E&E News (July 2, 2025), https://subscriber.politicopro.com/ article/eenews/2025/07/02/trump-admin-advances-overhaul-for-basis-of-climate-rules-cw-00435083 (on file with the Columbia Law Review); see also Lisa Friedman, Brad Plumer, Rebecca F. Elliott & Eric Lipton, Trump Signs Orders to Promote Fossil Fuels and End Climate Policies, N.Y. Times (Jan. 20, 2025), https://www.nytimes.com/2025/01/ 20/climate/trump-emergency-oil-gas.html (on file with the Columbia Law Review). The President has also begun the process of withdrawing from the Paris Climate Accords, as he did in his first administration, 18 Friedman et al., supra note 17. even though the United States is the largest historical emitter of greenhouse gases and remains the largest emitter per capita. 19 Michon Scott, Does It Matter How Much the United States Reduces Its Carbon Dioxide Emissions If China Doesn’t Do the Same?, Nat’l Oceanic & Atmospheric Admin. (Aug. 30, 2023), https://www.climate.gov/news-features/climate-qa/does-it-matter-how-much-united-states-reduces-its-carbon-dioxide-emissions [https://perma.cc/DE4C-DNJB]; Who Releases the Most Greenhouse Gases?, CFR Educ. (Oct. 10, 2024), https://education.cfr.org/learn/ reading/who-releases-most-greenhouse-gases [https://perma.cc/G3AD-DEEE]. The timing of these setbacks in reducing greenhouse gas emissions could not be worse. The United States was already facing a narrow window to avoid serious effects from climate change. 20 Brady Dennis, U.N. Report Warns Nations Have ‘Rapidly Narrowing Window’ to Cut Emissions, Wash. Post (Sep. 8, 2023), https://www.washingtonpost.com/ climate-environment/2023/09/08/un-climate-report-cut-emissions/ (on file with the Columbia Law Review); Chris Mooney & Harry Stevens, The U.S. Plan to Avoid Extreme Climate Change Is Running Out of Time, Wash. Post (July 18, 2022), https://www.washingtonpost.com/ climate-environment/2022/07/18/climate-change-manchin-math/ (on file with the Columbia Law Review); Brad Plumer, Raymond Zhong & Lisa Friedman, Time Is Running Out to Avert a Harrowing Future, Climate Panel Warns, N.Y. Times (Feb. 28, 2022), https://www.nytimes.com/2022/02/ 28/climate/climate-change-ipcc-un-report.html (on file with the Columbia Law Review). Even if a new president tries to restart the process of regulating greenhouse gas emissions in 2028, the federal government likely would not be able to implement meaningful federal emissions controls until well into the 2030s because of the plodding nature of the federal regulatory process and lengthy judicial review. 21 See Bethany A. Davis Noll & Richard L. Revesz, Regulation in Transition, 104 Minn. L. Rev. 1, 55 (2019) (discussing the long process of agency rulemaking and judicial review). The absence of U.S. leadership on climate reductions may make it difficult to ensure that other countries fulfill their commitments to reduce greenhouse gases. 22 See Kate Abnett & Virginia Furness, Trump’s Paris Climate Exit Will Hit Harder Than in 2017, Reuters (Jan. 21, 2025), https://www.reuters.com/world/ trumps-paris-climate-exit-will-hit-harder-than-2017-2025-01-21/ (on file with the Columbia Law Review) (explaining that U.S. withdrawal will increase the chance of global warming escalating, slow U.S. climate funding internationally, and leave investors struggling to navigate the divergence between European and U.S. green rules). All of this indicates that we are headed to a place where a warming world will upend the lives of Americans. 23 See Alexa K. Jay et al., Overview: Understanding Risks, Impacts, and Responses, in U.S. Glob. Change Rsch. Program, supra note 14, at 1-5 to -36.

Adapting to climate harms will not only require profound changes to our day-to-day experiences—they will cost money. As one example, climate change is intensifying storms, leading to more and more episodes of flash flooding just like Vermont experienced in 2023. 24 For a recent, tragic example, see Rebecca Hersher & Lauren Sommer, Floods Are Getting More Dangerous Around the Country, NPR, https://www.npr.org/2025/07/07/nx-s1-5459755/texas-floods-climate-change [https://perma.cc/A26D-H4MV] (last updated July 15, 2025) (connecting an extreme flooding episode in Texas on July 4, 2025, that killed dozens of people to a trend of increasing extreme rain storms resulting from climate change); see also supra notes 1–10 and accompanying text (discussing Vermont floods). The National Oceanic and Atmospheric Administration (NOAA) estimates that approximately one third of flood damage between 1995 and 2023 is attributable to climate change, totaling about $84 billion in 2023 alone. 25 Elizabeth A. Payton et al., Water, in U.S. Glob. Change Rsch. Program, supra note 14, at 4-17 fig.4-12. Yet flooding is only one of many harmful environmental and public health effects that will demand significant financial resources in the coming years. Climate change will also exacerbate numerous other natural disasters, such as wildfires, hurricanes, and heat waves, in addition to the more gradual harms such as sea-level rise, water scarcity, and crop losses. 26 On the refinement of techniques to attribute individual natural disasters to climate change, see Noah S. Diffenbaugh et al., Quantifying the Influence of Global Warming on Unprecedented Extreme Climate Events, 114 PNAS 4881, 4881 (2017). For a review of efforts to quantify the effects of climate on various societal outcomes, including on the economy and public health, see Tamma A. Carleton & Solomon M. Hsiang, Social and Economic Impacts of Climate, Science, Sep. 9, 2016, at 1, 11 (2016) (“[N]ew empirical measurements suggest that current climatic conditions impose substantial economic and social burdens on modern populations and that future climate change will further increase these ongoing costs considerably.”).

Who will pay for the costs of responding to these disasters and environmental changes? 27 Cf. Rebecca Henderson, Reimagining Capitalism in a World on Fire 20 (2021) (“Energy is cheap because we don’t pay its full costs.”). At present, taxpayers will be solely responsible for shouldering the severe financial burden of climate adaptation even though present and future populations have had a limited role in causing our predicament. 28 On the ethics of placing the burden of climate change on present and future generations, see Richard L. Revesz & Michael A. Livermore, Retaking Rationality: How Cost-Benefit Analysis Can Better Protect the Environment and Our Health 101, 107–17 (2008). This inequitable distribution of climate adaptation costs represents a profound economic, ethical, and policy failure. 29 For the ways in which climate justice concepts have drawn from the environmental justice movement, see David Schlosberg & Lisette B. Collins, From Environmental to Climate Justice: Climate Change and the Discourse of Environmental Justice, 5 WIREs Climate Change 359, 362 (2014). The inequitable distribution of climate adaptation costs is also a classic market failure, as companies are able to socialize the harms and costs of their activities while reaping private benefits. See R.H. Coase, The Problem of Social Cost, 3 J.L. & Econ. 1, 1–6 (1960) (theorizing that scenarios in which corporations are able to fully externalize their costs without incurring reciprocal costs “would not endure” in a functioning market economy). As documented by decades of scientific research, 30 See Naomi Oreskes, The Scientific Consensus on Climate Change, 306 Science 1686, 1686 (2004) (noting that, as of 2004, “all major scientific bodies in the United States” were in “scientific consensus on the reality of anthropogenic climate change”). the combustion of coal, oil, and natural gas over the course of the twentieth and twenty-first centuries is the primary cause of global warming. 31 See Intergovernmental Panel on Climate Change, Climate Change 2022: Mitigation of Climate Change 231 (2022) (explaining that about 62% of total greenhouse gas emissions from 1850 to 2019 occurred after 1970, with about 42% of total emissions occurring after 1990 and about 17% between 2010 and 2019); see also id. at fig.2.7(a) (showing the relative contributions of coal, oil, and gas to carbon dioxide emissions each year from 1850 to 2019, with the bulk of contributions occurring after 1950); Simon Pirani, Burning Up: A Global History of Fossil Fuel Consumption 54 (2018) (explaining that the vast majority of fossil fuel use has occurred since 1950 and that, between 1950 and 2000, it increased fivefold); Pierre Friedlingstein et al., Global Carbon Budget 2020, 12 Earth Sys. Sci. Data 3269, 3304 tbl.8 (2020) (illustrating cumulative fossil fuel carbon dioxide emissions since 1750, with the greatest emissions occurring in the period between 1959 and 2019); Leandro Vigna, Johannes Friedrich & Thomas Damassa, The History of Carbon Dioxide Emissions, World Res. Inst. (June 3, 2024), https://www.wri.org/
insights/history-carbon-dioxide-emissions [https://perma.cc/4L7V-YB5Z].
Companies that sell these products have netted large profits, with the top twelve firms earning more than $20 trillion in the last three decades. 32 Carl-Friedrich Schleussner, Marina Andrijevic, Jarmo Kikstra, Richard Heede, Joeri Rogelj, Holly Simpkin & Sylvia Schmidt, Climate Analytics, Carbon Majors’ Trillion Dollar Damages 11 (2023), https://ca1-clm.edcdn.com/assets/Carbon-majors%E2%80%‌99-trillion-dollar-damages-final.pdf?v=1700110774 [https://perma.cc/C72K-Z3RZ]. Regulations to curb future emissions will not remedy this extreme imbalance between fossil fuel companies’ revenues and the American public’s financial burden in paying for climate adaptation.

To address this issue, Vermont passed a first-of-its-kind law in May 2024 that will require fossil fuel companies to help pay for climate adaptation. 33 S. 259, 2023–2024 Gen. Assemb., Reg. Sess. (Vt. 2024). Called the Climate Superfund Act, it will shift a portion of the state’s climate adaptation costs to the companies most culpable for our current crisis. 34 Leah Sarnoff, Vermont Officially Becomes 1st State to Charge Big Oil for Climate Change Damage, ABC News (May 30, 2024), https://abcnews.go.com/US/vermont-bill-charge-big-oil-climate-change-damage/story?id=110148158 [https://perma.cc/X22S-DHUS]. Modeled on federal and state laws for hazardous waste, the state climate superfund program could support projects designed to avoid, moderate, or repair damage resulting from past fossil fuel use. 35 For an analysis of the ways in which climate adaptation legislation can build on the model of hazardous waste liability laws, see Anthony Moffa, From Comprehensive Liability to Climate Liability: The Case for a Climate Adaptation Resilience and Liability Act (CARLA), 47 Harv. Env’t L. Rev. 473, 477 (2023) (explaining that the paper will “make the first scholarly case for a Climate Adaptation Resilience and Liability Act,” a climate adaptation law, “by comparison to . . . CERCLA,” a hazardous waste liability law). It is based on a longstanding legal doctrine known as the “polluter pays” principle, which stipulates that the entities responsible for pollution should be financially liable for the resulting harms. 36 Boris N. Mamlyuk, Analyzing the Polluter Pays Principle through Law and Economics, 18 Se. Env’t L.J. 39, 41–42 (2009); see also Jonathan Remy Nash, Too Much Market?: Conflict Between Tradable Pollution Allowances and the “Polluter Pays” Principle, 24 Harv. Env’t L. Rev. 465, 466 (2000) (stating that the polluter pays principle “underlies much of modern environmental law”). The Organisation for Economic Cooperation and Development (OECD) originally developed the polluter pays concept in the early 1970s as a way of avoiding distortions in international trade, as well as addressing the market failure of pollution. See OECD, The “Polluter-Pays” Principle and the Instruments for Allocating Environmental Costs, in The Polluter Pays Principle 22, 22 (1975), https://www.oecd.org/content/dam/ oecd/en/publications/reports/1975/ 01/‌the-polluter-pays-principle_g1gh8f8f/9789264044845-en.pdf (on file with the Columbia Law Review). The Vermont law requires companies to pay a portion of the state’s climate change driven spending so long as they are responsible for selling fossil fuels above a specified level. The threshold is high enough to limit liability to only the largest, most profitable fossil fuel corporations, such as Exxon Mobil and Chevron.

Other states have begun to follow Vermont’s lead as they grapple with the effects of global warming. In December 2024, New York’s governor signed a similar bill to establish a state climate superfund over two years after state legislators first suggested creating such a program. 37 H. Claire Brown, New York Legislators Pass Climate Superfund Bill, Wall St. J. (June 11, 2024), https://www.wsj.com/articles/new-york-legislators-pass-climate-superfund
-bill-4547b80e (on file with the Columbia Law Review); Hilary Howard, Hochul Signs Law that Penalizes Companies for Greenhouse Gas Emissions, N.Y. Times (Dec. 26, 2024), https://www.nytimes.com/2024/12/ 26/nyregion/hochul-climate-change-superfund-law.html (on file with the Columbia Law Review); Press Release, Liz Krueger, Krueger, Dinowitz Introduce Nation-Leading Climate Change Superfund Act, N.Y. St. Senate (May 26, 2022), https://www.nysenate.gov/ newsroom/video/liz-krueger/krueger-dinowitz-introduce-nation-leading-climate-change-superfund-act [https://perma.cc/BV7H-8EDF].
State legislators in nearly a dozen other states have also drafted and introduced similar bills in the last few years as their states face mounting environmental and public health threats from global warming. 38 The list of states is growing and currently includes California, Connecticut, Hawaii, Illinois, Maryland, Massachusetts, New Jersey, Oregon, Rhode Island, Tennessee, and Virginia. See Alex Brown, Climate Disasters Are on the Rise. These States Want to Make Oil Companies Pay., Stateline (Mar. 31, 2025), https://stateline.org/‌2025/03/31/
climate-disasters-are-on-the-rise-these-states-want-to-make-oil-companies-pay/ (on file with the Columbia Law Review); Karen Zraick, Climate ‘Superfund’ Bills Spread Nationwide, Despite Legal Battles, N.Y. Times (Feb. 6, 2026), https://www.nytimes.com/‌2026/02/06/climate/climate-superfund-laws-bills.html (on file with the Columbia Law Review).
Given the severity of the climate crisis and the failure of numerous federal efforts to adequately address the problem, these state initiatives may become the most significant environmental legislation in a generation. 39 The relative significance of legislation is, of course, subjective. But the only other major contender in the area of environmental law would have been the 2023 Inflation Reduction Act, which sought to use the federal government’s spending power to spur clean energy development. Congress and President Trump, however, repealed most of these provisions before they had a chance to make a large difference in reducing greenhouse gas emissions, despite the benefits of the bill going to mostly Republican states and districts. For an analysis of the effects of this repeal, see Jesse D. Jenkins, Jamil Farbes & Ben Haley, Impacts of the One Big Beautiful Bill on the US Energy Transition—Summary Report 4 (2025), https://zenodo.org/records/ 15801701/files/REPEAT_‌OBBB_07-03-25.pdf (on file with the Columbia Law Review) (explaining that the repeal will raise greenhouse gas emissions as well as household energy expenses while reducing energy capacity); see also Lisa Friedman, Repeal of Clean Energy Law Will Mean a Hotter Planet, Scientists Warn, N.Y. Times (June 20, 2025), https://www.nytimes.com/2025/06/‌ 20/climate/inflation-reduction-act-climate-change-heat.html (on file with the Columbia Law Review).

This Article examines the development of state climate superfund laws and explores the legal and policy issues raised by such legislation, including the choices states will need to make about how to design these laws and the potential legal challenges they will face. In addition to analyzing the history of similar environmental legislation and litigation over its constitutionality, the Article also draws on the author’s experience providing legal advice and assistance to states seeking to pass these laws. 40 Since joining the University of Michigan, the author has provided this legal advice completely pro bono. Prior to her professorship, the author worked as a legal fellow at the Institute for Policy Integrity, which received funding from a philanthropic organization—the Rockefeller Family Fund—to provide legal advice about state climate superfund legislation. That grant was $25,000 and helped to defray a portion of the author’s annual salary as well as administrative overhead.

The author further declares that she has received no funding in connection with this Article and that no environmental organizations or state legislators have provided feedback, input, or oversight of any kind regarding its contents. The views in this Article are the author’s own and should not be taken to represent the position of any state official involved in drafting these laws or organizations advocating for or against their passage.

Industry groups, notably the American Petroleum Institute and U.S. Chamber of Commerce, have argued that state climate superfunds are unconstitutional on multiple grounds. 41 Complaint for Declaratory and Injunctive Relief at 4–7, Chamber of Com. v. James, No. 1:25-cv-01738 (S.D.N.Y. filed Feb. 28, 2025), Dkt. No. 1 (arguing that state climate superfunds violate the Due Process Clause of the Fourteenth Amendment, the Takings Clause of the Fifth Amendment, the Commerce clause, and the Eighth Amendment’s prohibition on excessive fines); Complaint for Declaratory and Injunctive Relief at 3–5, Chamber of Com. v. Moore, No. 2:24-cv-01513-mkl (D. Vt. filed Dec. 30, 2024), Dkt. No. 1 (same); see also Memorandum in Opposition, Am. Petroleum Inst., Senate Budget S. 4008 B, Transportation, Economic Development and Environmental Conservation Budget (TED), Part JJJ “Climate Change Superfund Act” (Mar. 2023) (on file with the Columbia Law Review) (same). They are currently suing both Vermont and New York to stop implementation of the laws alongside twenty two Republican state attorneys general. 42 Complaint for Declaratory and Injunctive Relief, West Virginia v. James, No. 1:25-cv-00168-BKS-DJS (N.D.N.Y. filed Feb. 6, 2025), 2025 WL 430926 (filed by the attorneys general of twenty two states). Republican attorneys general subsequently intervened in the ongoing Chamber of Commerce and American Petroleum Institute litigation against Vermont. See Complaint in Intervention for Declaratory and Injunctive Relief, Chamber of Com. v. Moore, No. 2:24-cv-01513-mkl (D. Vt. filed May 1, 2025), Dkt. No. 27-2 (filed by attorneys general of twenty four states; Alaska and Indiana joined the Vermont lawsuit and were not originally parties to the New York lawsuit); see also Adam Aton, Red States Follow Trump’s Fight Against Climate Superfund Law in Vermont, E&E News (May 2, 2025), https://www.eenews.net/articles/red-states-follow-trumps-fight-against-climate-superfund-law-in-vermont/ (on file with the Columbia Law Review). In an unprecedented step, the Department of Justice (DOJ) has brought a similar lawsuit against Vermont and New York, arguing that the federal government has exclusive authority to address climate change. 43 Adam Aton, DOJ Sues to Block State ‘Climate Superfunds’, E&E News (May 2, 2025), https://subscriber.politicopro.com/ article/eenews/2025/05/02/doj-sues-to-block-state-climate-superfunds-00323012 (on file with the Columbia Law Review). The extraordinary effort to prevent states from enacting these laws makes clear the considerable legal and financial stakes of state climate superfunds. Beyond the implications for balancing federal and state authority over environmental issues, this litigation could have consequences for other horizontal and vertical federalism disputes. 44 On the emergence of legal scholarship about “horizontal federalism,” see Heather K. Gerken & Ari Holtzblatt, The Political Safeguards of Horizontal Federalism, 113 Mich. L. Rev. 57, 59–65 (2014) (noting how “courts and scholars have neglected federalism’s horizontal dimensions” and providing a “political-safeguards account for horizontal federalism”). For a discussion of the problem of “fair weather” federalism, see Jonathan H. Adler, Are Nebraska and Oklahoma Just Fair-Weather Federalists?, Wash. Post (Dec. 19, 2024), https://www.washingtonpost.com/ news/volokh-conspiracy/wp/2014/‌12/19/are-nebraska-and-oklahoma-just-fair-weather-federalists/ (on file with the Columbia Law Review) (“Principled arguments for state autonomy necessarily allow for one state to make policy choices that those in other states may not like.”). Should states be able to impose civil penalties on an out-of-state abortion provider if she mails mifepristone into another state? 45 See, e.g., Katherine Florey, Dobbs and the Civil Dimension of Extraterritorial Abortion Regulation, 98 N.Y.U. L. Rev. 485, 488 (2023) (explaining that “few constitutional obstacles” currently exist if states wish to impose civil liability on out-of-state abortion providers). What about state liability for hackers who obtain private material from someone in another state and share it without consent? 46 Such information could include business, medical, or personal data. For an example involving personal photos, see Amanda L. Cecil, Note, Taking Back the Internet: Imposing Civil Liability on Interactive Computer Services in an Attempt to Provide an Adequate Remedy to Victims of Nonconsensual Pornography, 71 Wash. & Lee L. Rev. 2513, 2515 (2014) (describing how a woman in Texas was victimized by a hacker who shared partially nude photos without her consent). Though answering these questions is outside the scope of this Article, it is worth noting that federalism disputes over state climate superfunds could influence constitutional doctrines governing a wide range of state lawmaking authority. 47 See, e.g., Allan Erbsen, Horizontal Federalism, 93 Minn. L. Rev. 493, 495–96 (2008) (providing a model for analyzing jurisprudence on horizontal federalism issues).

The Article begins by detailing the growing costs of climate change to states and how these financial challenges have led lawmakers to consider passing climate superfund bills. These legislative initiatives will become even more important in the coming years should President Trump follow through on his threat to significantly reduce or eliminate federal disaster assistance. 48 Indeed, Project 2025—a blueprint for Trump’s second term—recommended shifting more natural disaster costs to states. See Christopher Flavelle, Trump Says States Should Manage Disasters and Weighs Shuttering FEMA, N.Y. Times (Jan. 24, 2025), https://www.nytimes.com/live/2025/ 01/24/us/los-angeles-wildfires-california (on file with the Columbia Law Review) (citing President Trump’s hiring of the chief architect of Project 2025 as head of OMB, and the President’s statement suggesting that “you want to use your state to fix” problems such as the 2024 California wildfires, and “recommend[ing] that FEMA go away”(internal quotation marks omitted)). Part II provides a historical and theoretical justification for state leadership on climate superfund legislation, including states’ longstanding role in protecting their residents and natural resources from external threats as well as the benefits of policy innovation through state experimentation with superfund design. It also argues that climate change, while global in its origins, is inherently a matter of local concern because of its diverse, unequal effects on natural resources and public health. The local nature of the harm further supports state leadership in holding responsible parties accountable.

Fossil fuel companies, Republican attorneys general, and the DOJ have challenged these laws on a number of constitutional grounds, such as claiming that state climate superfunds infringe on companies’ due process rights, violate the dormant Commerce Clause, and are preempted by federal legislation. 49 On the embedded normative values in such constitutional disputes, see Robert Post & Reva Siegel, Roe Rage: Democratic Constitutionalism and Backlash, 42 Harv. C.R.-C.L. L. Rev. 373, 378 (2007) (explaining that legal interpretation of open-ended provisions “typically involves the expression of national values like equality, liberty, dignity, family, or faith”). Part III examines these legal issues and analyzes whether state climate superfunds differ in relevant respects from other environmental legislation that has survived similar constitutional challenges. Part IV concludes by exploring the key decisions states are facing as they draft such legislation, including how to define “responsible parties” liable for cost recovery demands, how to apportion liability among fossil fuel companies, and how to distribute funds among various adaptation projects. It offers economic, ethical, and policy rationales for designing the laws in certain ways and suggests the best options for states to recoup a fair portion of their costs while ensuring these laws stand up to legal scrutiny.