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TheCorporateCounsel

TheCorporateCounsel.net

A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.

DealLawyers

DealLawyers.com

An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.

CompensationStandards

CompensationStandards.com

The “one stop” resource for information about responsible executive compensation practices & disclosure.

Section16.net

Section16.net

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.

PracticalESG

PracticalESG.com

Keeping you in-the-know on environmental, social and governance developments

California’s climate disclosure law, SB 253, and its climate risk disclosure law, SB 261, face new legal challenges brought by ExxonMobil. The lawsuit alleges that the laws are unconstitutional, arguing that they violate the First Amendment and the National Securities Market Improvement Act. Responsible Investor summarizes the arguments:

“The rules ‘compel ExxonMobil to produce reports on a topic of intense political debate that it would otherwise not produce and with which it fundamentally disagrees’, the firm said. As a result,  it argued, SB 253 violates its First Amendment rights… On SB 261, the firm claims the rules violate the National Securities Markets Improvement Act, which preempts state laws from imposing enhanced investor reporting requirements over federal disclosures.

More broadly, Exxon disputes the idea that the requirements would be useful for consumer or investor protection. ‘California has no constitutionally adequate justification for the speech burdens SB 253 and SB 261 impose,’ it said.”

The First Amendment argument is very similar to the argument made by the California Chamber of Commerce in its ongoing lawsuit challenging the laws. First Amendment claims were also successful in fighting the SEC conflict minerals rule a decade ago. However, the National Securities Markets Improvement Act argument was not featured in previous litigation. So far, the California laws have fared well in the courts. In November of last year, the courts chose not to enjoin the law pending the outcome of litigation, which means that both laws are set to go into effect next year. Additionally, of the Chamber’s three original arguments, only one survived dismissal. We’ll see if and how the Exxon litigation differs and if Exxon will have more success stopping the laws than the Chamber of Commerce.

Our members can learn about SB 253 and SB 261 here.

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The Editor

Zachary Barlow is a licensed attorney. He earned his JD from the University of Mississippi and has a bachelor’s in Public Policy Leadership. He practiced law at a mid-size firm and handled a wide variety of cases. During this time he assisted in overseeing compliance of a public entity and litigated contract disputes, gaining experience both in and outside of the courtroom. Zachary currently assists the PracticalESG.com editorial team by providing research and creating content on a spectrum of ESG… View Profile