Rocky Mountain Farmers Union, et al. v. Goldstene, et al., No. CV-F-09-2234 LJO GSA, 2011 U.S. Dist. LEXIS 149590 (E.D. Cal. Dec. 29, 2011)

(court holds that California's Low Carbon Fuel Standard violates Commerce Clause because legislation based on lifecycle analysis of fuels would result in ethanol market becoming "Balkanized" by having producer either relocate operations in state of largest use or sell locally to avoid transportation and other penalties; as such, Standard would interfere with the "maintenance of a national economic union unfettered by state-imposed limitations on interstate commerce"; state sought to control conduct beyond boundary of state by regulating "dirtier" Midwest-produced ethanol in attempt  to regulate greenhouse gas emissions; facts established that ethanol produces more greenhouse gas emissions than does gasoline).