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Record W3124708772

Kivalina V. Exxonmobil: A Comparative Case Comment

2013· article· en· W3124708772 on OpenAlexaboutno aff
Karine Péloffy

Bibliographic record

VenueSSRN Electronic Journal · 2013
Typearticle
Languageen
FieldSocial Sciences
TopicEnvironmental law and policy
Canadian institutionsnot available
Fundersnot available
KeywordsCommon lawFederal common lawNuisancePolitical scienceLawTortLegislationEnvironmental lawLegislatureClimate justiceLiabilityClimate change
DOInot available

Abstract

fetched live from OpenAlex

1. INTRODUCTION 2. CLIMATE CHANGE GOVERNANCE IN AMERICAN COURTS 2.1 Kivalina, Climate Change and the Common Law of Public Nuisance 2.2 Kivalina v. ExxonMobil, the Death of Environmental Common Law? 2.3 Securing Climate Mitigation Through Judicial Review of Executive Inaction 2.4 Denying Access to Courts for Climate Victims in Need of Adaptation 3. CLIMATE NUISANCE CLAIMS MIGRATING NORTH TO CANADA? 3.1 Climate Change Litigation in a Legislative Vacuum 3.2 Kivalina v. Exxonmobil-like Hypothetical Lawsuit: Tux v. Oil Sands 3.3 Crown Tort Liability for Failure to Govern a Public Nuisance 3.4 Additional Constitutional Grounds for Action Against the Federal Crown 3.5 Availability of both Compensatory and Injunctive Remedies 3.6 Obstacles to Access to Justice in Multijurisdictional Litigation 3.7 The Birth of Federal Common Law of Interprovincial Pollution in Canada 3.8 Environmental Common Law Stands Unimpeded by Legislation 4. WHERE TO FROM HERE? CLIMATE CHANGE AND COMMON LAW JUDGES 4.1 Comparative Federal Common Law of Transboundary Nuisance 4.2 Obstacles Ahead in Climate Change Litigation 4.3 Justiciability: the Thin Line Between Law and Politics 4.4 Attributing Loss in a World of Victims and Perpetrators 5. CONCLUSION Our conclusion obviously does not aid Kivalina, which itself is being displaced by the rising sea. But the solution to Kivalina's dire circumstance must rest in the hands of the legislative and executive branches of our government, not the federal common law. (1) Hence concluded the judgment that nailed the coffin shut of one of the most important and interesting legal cases in recent history. It had the trappings of a David and Goliath battle, pitting a small Inuk village threatened by the rising seas of the rapidly warming Arctic against some of the largest multinational corporations. (2) Due to its fact situation and legal argumentation, Native Village of Kivalina v. ExxonMobil Corp. (3) was heralded as the ultimate refinement of climate change litigation strategy, the ultimate test case for climate justice relief. (4) So far, it has suffered three consecutive defeats on jurisdictional grounds. Climate change may well be the most pressing global problem of our time. (5) Since the major impacts are only perceived to be far in the future, the governments arguably most responsible for climate change can refuse to enact comprehensive laws that would effectively govern the issue without incurring popular disapproval. When governments fail to act, the injurious status quo persists, and victims have no choice but to seek remedial action through the courts. (6) How may North American judges, faced with an executive and legislative failure to govern the most complex and important problem mankind has ever faced, evaluate the claims of climate change victims? (7) This comment undertakes a comparative analysis of the recent appellate decision in the American case Kivalina v. Exxonmobiland a hypothetical Canadian case, based on the Supreme Court jurisprudence of both countries. This comment focuses on the ability of climate change litigants to use the common law to access the courts, and on the evolution of jurisprudential trends enabling climate change governance in the face of political inaction. This comment suggests: (1) that Kivalina's recent defeat could herald the end of environmental common law in the United States, and (2) that Canada may offer a more welcoming legal climate for similar claims. Importantly, this comment does not speculate on the likelihood of success of climate litigants in either country. 2. CLIMATE CHANGE GOVERNANCE IN AMERICAN COURTS 2.1 KIVALINA, CLIMATE CHANGE AND THE COMMON LAW OF PUBLIC NUISANCE While the world is experiencing increases in temperature due to greenhouse gas (GHG) emissions, the Arctic is warming at approximately twice the global rate. …

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How this classification was reachedexpand

Full frame distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.001
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Theoretical or conceptual · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: Empirical
Teacher disagreement score0.644
Threshold uncertainty score0.999

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0010.000
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0010.000
Scholarly communication0.0000.000
Open science0.0000.000
Research integrity0.0000.001
Insufficient payload (model declined to judge)0.0010.001

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.023
GPT teacher head0.321
Teacher spread0.298 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one teacher head, not a consensus.

The models applied no category: nothing in the taxonomy fit this work.
Study designTheoretical or conceptual
Domainnot available
GenreEmpirical

How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".

Quick stats

Citations2
Published2013
Admission routes1
Has abstractyes

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