Summary of holding
The Supreme Court held that Puerto Rico’s quasi-sovereign interests were violated in two ways that each supported the establishment of standing under the doctrine of parens patriae:
- First, the definition of a State’s interests in the health and well-being of its citizens reaches both physical and economic interests. This means that it can act to protect its residents from “the harmful effects of discrimination” (¶ 609). There is no defined proportion of the population that must be adversely affected to qualify. Even though the financial loss at issue here was relatively limited, the Court found that “deliberate efforts to stigmatize the labor force as inferior carry a universal sting” (¶ 609).
- Second, the State has standing to pursue the full and equal protection of its citizens in the federal employment service scheme established by federal law. The Wagner-Peyser Act and the Immigration and Nationality Act of 1952 provide, in part, that US workers should be given preference over foreign workers. The Court found that unemployment among Puerto Rican residents is “surely a legitimate object of the Commonwealth’s concern” (¶ 609).
Potential takeaways for future climate migration litigation
Standing for States to bring suit for climate-related harms. This case is significant for describing the types of quasi-sovereign interests sufficient to establish parens patriae standing. Physical and economic health and well-being interests should extend to significant harms resulting from climate change that necessitate human migration. This could encompass such physical injuries as the threat to human health and safety as well as economic harms resulting from the upheaval of communities, destruction of industry and infrastructure, and adaptive measures in reacting to displaced citizens.