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Department of the Air Force, et al. v. Prutehi Guahan, fka Prutehi Litekyan

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 22-16613 · judgment February 13, 2025


Set for argument · October 7, 2026
Pre-decision estimate: 5% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for counsel who has won certiorari before and a Ninth Circuit decision below.

Questions presented

The Resource Conservation and Recovery Act of 1976 (RCRA), 42 U.S.C. 6901 et seq., is a comprehensive environmental statute providing for cradle-to-grave regulation of hazardous waste through a scheme of cooperative federalism. Under RCRA, the United States Environmental Protection Agency may authorize state and territorial regulators to administer permitting programs for hazardous-waste-treatment facilities in their respective jurisdictions, including facilities operated by the federal government. The questions presented are as follows:

  1. Whether the federal government's submission to a state or territorial regulator of an application to renew a RCRA permit is "final agency action" that is immediately reviewable under the Administrative Procedure Act, 5 U.S.C. 704.

  2. Whether the federal government must comply with the general environmentalreview procedures of the National Environmental Policy Act of 1969, 42 U.S.C. 4321 et seq., before submitting a permit-renewal application under RCRA, which sets forth its own specific procedures to review environmental impacts in the context of hazardous-waste treatment.

Counsel of record

For petitioner
D. John Sauer
Solicitor General

For respondent
Caroline Anne Flynn
Earthjustice

Case

Conference history
Distributed for 3 conferences

Amicus briefs
8 merits
(3 supporting pet./neither, 5 respondent)

Linked docket
25A374

Proceedings

  1. Aug 20 2026
    Record received from the United States Court of Appeals for the Ninth Circuit. The record is electronic and is available on PACER.
  2. Aug 19 2026
    Reply of petitioners United States Department of the Air Force, et al. filed. (Distributed)
  3. Aug 12 2026
    CIRCULATED
  4. Aug 12 2026
    Record requested from the United States Court of Appeals for the Ninth Circuit.
  5. Aug 04 2026
    SET FOR ARGUMENT on Wednesday, October 7, 2026.
  6. Jul 27 2026
    Brief amicus curiae of Virgin Islands Bar Association filed.
  7. Jul 27 2026
    Brief amici curiae of Washington, et al. filed.
  8. Jul 27 2026
    Brief amici curiae of Community-Based Organizations in Guam, et al. filed.
  9. Jul 27 2026
    Brief amici curiae of Jared Huffman, et al. filed.
  10. Jul 24 2026
    Brief amicus curiae of Blue Ocean Law filed.
  11. Jul 20 2026
    Brief of respondent Prutehi Guahan filed.
  12. May 29 2026
    Brief amici curiae of Chamber of Commerce of the United States, et al. filed.
  13. May 29 2026
    Brief amici curiae of West Virginia, et al. filed.
  14. May 29 2026
    Brief amici curiae of The Foundation for American Innovation, et al. filed.
  15. May 22 2026
    Brief of petitioners United States Department of the Air Force, et al. filed.
  16. May 22 2026
    Joint appendix filed.
  17. Mar 24 2026
    Motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioners' brief on the merits is extended to and including May 22, 2026. The time for filing respondent's brief on the merits is extended to and including July 20, 2026.
  18. Mar 20 2026
    Motion for an extension of time to file the briefs on the merits filed.
  19. Mar 09 2026
    Petition GRANTED.
  20. Mar 02 2026
    DISTRIBUTED for Conference of 3/6/2026.
  21. Feb 23 2026
    DISTRIBUTED for Conference of 2/27/2026.
  22. Feb 04 2026
    DISTRIBUTED for Conference of 2/20/2026.
  23. Feb 04 2026
    Reply of petitioners United States Department of the Air Force, et al. filed. (Distributed)
  24. Jan 16 2026
    Brief of respondent Prutehi Guahan in opposition filed.
  25. Dec 04 2025
    Motion to extend the time to file a response is granted and the time is extended to and including January 16, 2026.
  26. Dec 03 2025
    Motion to extend the time to file a response from December 17, 2025 to January 16, 2026, submitted to The Clerk.
  27. Nov 14 2025
    Petition for a writ of certiorari filed. (Response due December 17, 2025)
  28. Oct 01 2025
    Application (25A374) to extend the time to file a petition for a writ of certiorari from October 15, 2025 to November 14, 2025, submitted to Justice Kagan.
  29. Oct 01 2025
    Application (25A374) granted by Justice Kagan extending the time to file until November 14, 2025.