Loorz, et al. v. Perciasepe, No. 11-cv-2235, 2013 U.S. Dist. LEXIS 72301 (D. D.C. May 22, 2013)

(environmental activist organizations sued the Administrator of the federal EPA seeking declaratory and injunctive relief for defendant's alleged failure to reduce greenhouse gas emissions; theory advanced was that, as federal officers, defendant violated fiduciary obligations to protect the atmosphere under the federal public trust doctrine; federal court dismissed action based on finding that claims based on state common law rather than federal law and dismissed case; plaintiffs sought reconsideration under federal rules; court declined motion for reconsideration because plaintiffs failed to present change in law or clear error).