In G.B. by & through G.P. v. United States Env’t Prot. Agency, No. 25-2473, 2026 WL 959839 (9th Cir. Apr. 9, 2026), the Ninth Circuit for the United States Court of Appeals affirmed dismissal of a constitutional challenge brought by a group of minors against the Environmental Protection Agency (“EPA”) and related federal entities. The plaintiffs alleged that the federal government’s use of cost-benefit discounting in environmental rulemaking unlawfully discriminates against children and contributes to climate-related harm.

The plaintiffs challenged federal guidelines—primarily the Office of Management and Budget (“OMB”) Circular A-4 guideline and the EPA economic analysis guideline—that permit agencies to discount future costs and benefits when evaluating regulations. The plaintiffs argued that discounting inherently favors present-day interests over future harms, resulting in weaker greenhouse gas (“GHG”) regulations and disproportionate harm to younger generations. The plaintiffs sought declaratory and injunctive relief barring the use of discounting in climate-related analyses.

The Ninth Circuit rejected these claims, holding that the plaintiffs lacked Article III standing. First, the Court held that the plaintiffs failed to allege a cognizable injury-in-fact. The Court explained that discounting is a facially neutral economic tool grounded in accepted principles such as the time value of money. The plaintiffs failed to plausibly allege that the government adopted or applied discounting with discriminatory intent toward children. At most, plaintiffs alleged a disproportionate impact, which is insufficient to establish a constitutional violation.

Second, the Court found the plaintiffs’ theory of causation too speculative. Their claims relied on a multi-step chain of assumptions, including that the EPA would issue future GHG regulations, rely on discounted analyses, and that such reliance would result in weaker regulations causing climate harm. The Court held that this attenuated chain of possibilities does not satisfy Article III’s traceability requirement. Third, the Court held that the requested declaratory relief would not redress the plaintiffs’ alleged injuries. Relying on Juliana v. United States, 947 F.3d 1159 (9th Circ. 2020), the Court concluded that invalidating the discounted policies would not meaningfully mitigate the plaintiffs’ climate-related harms absent further judicial intervention.

This case is an example that policy-based challenges to regulator frameworks, particularly those grounded in economic methodologies, face substantial standing barriers absent a direct connection to a specific regulatory action. Future climate claims must target discrete agency actions rather than broad policy frameworks. The Court reaffirmed that disputes over how agencies weight long-term environmental harm against present-day costs are policy questions for political branches, not the judiciary.