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Although not as prominent in the public eye as automobile engines, emissions from non-road engines contribute significantly to global air pollution. In 2005, the United States Government fined Volvo Powertrain Corp. seventy-two million dollars for manufacturing non-road engines at its foreign subsidiary because these engines were not in compliance with emissions standards and therefore violated a consent decree between Volvo Powertrain Corp. and the federal government. In United States v. Volvo Powertrain Corp., the United States Court of Appeals for the D.C. Circuit upheld an interpretation of the consent decree and financial penalty put forth by the lower court. This Comment argues that the D.C. Circuit Court of Appeals was correct in holding Volvo Powertrain liable for the emissions violations of its subsidiaries’ engines. Volvo Powertrain subjected itself to United States jurisdiction by requesting certificates of emissions compliance from the Environmental Protection Agency for the engines manufactured abroad by their foreign subsidiary.


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8 Sep 2022
310 kB



  • Subject
    • Courts

    • Energy and Utilities Law

    • Environmental Law

    • Natural Resources Law

  • Journal title
    • Boston College Environmental Affairs Law Review

  • Volume
    • 44

  • Issue
    • 1

  • Pagination
    • 195

  • Date submitted

    8 September 2022