The U.S. Court of Appeals for the Ninth Circuit affirmed September 21 the dismissal of a claim of public nuisance for global warming caused by greenhouse gas emissions. The court argued that the claim, which was brought by the Alaskan Village of Kavalina against ExxonMobil, is displaced by the Clean Air Act and actions taken by the Environmental Protection Agency. The Court’s argument for dismissal is in accordance with the reasoning used in the Supreme Court’s 2011 ruling in American Electric Power Co. v. Connecticut.