Legal implications of the climate-health crisis: A case study analysis of the role of public health in climate litigation

The changing role of environmental and human rights law in litigation. Our results confirm reported trends attesting to a substantive rise in the contributions of environmental and human rights law to legal argumentation in litigation. Regarding human rights, several powerful case studies illustrate a trend towards petitioners increasingly employing rights claims in climate change lawsuits. In the Urgenda case (Table 1, case 1), the courts decided that human rights, which include the “right to health” is linked with decarbonization. In a case brought by Friends of the Irish Environment [89], the courts held that Ireland’s national mitigation plan partially violated statutory law, because it was not set to reduce GHG emissions sufficiently over the near term. In this case, human rights were used as part of the justification. In the case of Maria Khan et al. v the Federation of Pakistan (Table 1, case 3), rights to life, dignity, and a clean and healthy environment were argued to be under threat by the actions of the defendants. Likewise, the constitutionally guaranteed “Right to Life” is evoked in the legal argumentation of Future Generations v Ministry of the Environment (Table 1, case 2), as is “Article 2(2) of the Basic Law: Right to Life and Physical Integrity” in the lawsuit filed against District of Columbia vs. Exxon Mobil Corp. (Table 1, case 5). In their analysis of other rights- based claims in climate litigation cases, Peel and Osofsky (2017) conclude that receptivity of

courts to rights-based framing is on the rise because it provides a “tangible legal framework for analyzing state actions that lead to climate change” [90]. This is encouraging from a public health standpoint, as all UN human rights treaty bodies now recognize individual rights to life, health, food, and water [49, 91], providing a stronger legal avenue for plaintiffs to link claims of health threats to rights-based legal frameworks. Human rights have also been used by the defense in ‘just transition litigation’ to question the “benefits and burdens of the transition away from fossil fuels and towards net-zero emis- sions” [92]. Public health science can provide critical evidence to ensure that human rights are protected, defended and upheld. That defensive interests do not succeed in using a human rights narrative, when it is corporate rights that are at stake, and not human well-being. In relation to rights for nature, we also observed a rise in eco-centric framings of the envi- ronmental. This included the attribution of personhood to nature in some of the more recent cases and the recognition of the inherent value of the environment independent of ecosystem services. PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 17 / 31

In the case of Future Generations v Ministry of the Environment (Table 1, case 2), a group of youth plaintiffs in Colombia sued the government, municipalities and several corporations based on a “right to a healthy environment, life, health, food and water”. The court determined that the “fundamental rights to life and health are linked and determined by the environment and ecosystem”. The court further recognized the Colombian Amazon as subject to rights. There are similar cases in India, Bangladesh, Colombia, Ecuador, and New Zealand. In Modh Salim v State of Uttarakhand, the court declared two rivers to be ‘juristic/legal persons/ living entities having the status of a living person with all corresponding rights, duties and lia- bilities”. In 2017 the Whanganui river in New Zealand, the Ganges and Yamuan rivers in India, and the Rio Atrato in Colombia were also granted legal rights [93]. Globally, less than 15% of the land, 21% of the freshwater and 8% of the ocean are protected areas [34]. Yet, indigenous communities, which make up 5% of the global population hold 25% of the land, with 80% of planetary biodiversity. Many of the first countries to adopt rights for nature are post-colonial nations with living indigenous cultures. In the US, which constitutes the majority of litigation cases, 70% of litigation based on fed- eral statute is brought under the National Environmental Policy Act and Clean Air Act, which are more anthropocentric in their objectives [94]. However, it is likely that the codification of

eco-laws, in the US at the local level, will bring challenging cases before the courts on the issue of personhood for nature. Reconciling social and environmental justice. The trend in the growing volume of cases brought by, or on behalf of youth, introduces the concept of intergenerational equity. The UN convention on the rights of the child holds that “state parties shall undertake all appropriate legislative, administrative and other measures for the implementation of the rights recognized in the convention” [95]. In addition, the concept of intergenerational equity, is at the core of both the UN Charter and the Stockholm declaration on the environment: “the present genera- tion has a right to use and enjoy the resources of the Earth but is under an obligation to take into account the long-term impact of its activities and to sustain the resource base and the global environment for the benefit of future generations of humankind” [96]. The right to a healthy environment is now recognized in law by more than 80 percent of United Nations Member States (156 out of 193) [97]. In the case of Saachi v Argentina [98], 16 children filed a petition through the UN conven- tion on the rights of the child. The violated rights included “the right to life, right to health, pri- oritization of the child’s best interest, and cultural rights of petitioners from indigenous countries”. In the case of Future generations v Ministry of the Environment (Table 1, case 2), a group of plaintiffs aged between 7 and 26 years claimed the rights to a healthy environment,

life, health, food and water. In the case of Youth for Climate Change v EU [99], a group of youths claimed that the impact of climate change upon them would go as far as harming their mental health. Considering that the environmental impact will disproportionately affect certain communi- ties, there are cases of climate litigation that have been brought by groups that include: women, climate refugees, elderly women, organic farmers, indigenous people, and civil society. In most rulings, the courts have declined to give such groups unique standing to bring a case, for example by stating that all people will be impacted by climate change. Therefore, the strategy of framing the issue as one of disproportionate impact has not yet proven to be highly effective. However, the impact of climate litigation in generating media coverage, creating publicity, and changing public perception is evidently growing and can be expected to escalate further. PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 18 / 31

The role of public health in climate litigation Climate litigation through a public health lens. Despite growing awareness of health impacts of climate change, the public health lens is yet to be widely adopted by plaintiffs. Our study revealed that only 65 (3.96%) of the 1641 cases used a litigation strategy which included climate change at the center, with extensive use of the word “health” mentioned in the case file submitted to the court. We identified a rise in explicitly health-linked cases over recent years. This rise is consistent with the general increase in litigation cases and is not specific to liti- gation pursued on public health grounds. In their study on the role of health in climate litigation, McCormick et al. (2018) found that the Clean Air Act (CAA) was used to support 32% of all cases in the US in which litigants relied on health concerns to support their claims [100]. Interviews with plaintiffs revealed that their primary incentive for pursuing cases under the CAA was that, unlike laws such as the California Environmental Quality Act and the National Environmental Policy Act, the CAA has the protection of public health as its principle goal [100]. This shows that where health is the main focus of a given legal doctrine or environmental regulation, there exists a more direct and powerful avenue for individuals to pursue litigation on the basis of health concerns. Receptivity of courts to public health-framed argumentation. Amongst the 65 directly health-linked cases, there were 11 wins, 11 losses and 43 remain undetermined. The low num-

ber of directly health-linked climate cases and the number where decisions are pending, pre- cludes accurate assessment of trends in the receptivity of courts to public health-framed argumentation. The early successes, such as Urgenda Foundation v State of the Netherlands (Table 1, case 1) and other cases are testament to the potential power of public health claims in legal argumentation, yet it remains premature to conclude whether or not public health argu- ments presented to courts will be seen with the credibility and weight that they warrant. Nonetheless, one may postulate that as climate-health science matures, making clearer the links on which legal claims rest, the receptiveness of courts to public health language may rise. While McCormick et al. found that cases in which health was an issue had a win rate nearly the same as that for non-health cases (31% and 30%, respectively) [100], claims made by liti- gants attested to the perceived power of health risk attributions in legal argumentation. As stated, many litigants were “motivated to include health allegations in climate cases because they make the consequences of unabated climate change tangible and may increase the chances that courts will grant the relief sought by satisfying the substantive criteria needed to achieve success on the legal merits of the claim” [100]. Additionally, McCormick et al. noted that several cases in the database that centered on claims about contaminated water and used health as a central argument were won by plaintiffs seeking improved protections for local communities [100].

We contend that health ought to have a bearing on court rulings given the inherent political salience it holds. In his review of fishery management law, Craig (2014) argues that when it comes to advocating for laws targeted at ocean-focused climate change adaptation, a public health connection can provide “a political saliency and importance that is often otherwise missing” [101]. Likewise, Nosek (2018) argues that, so long as health threats in litigation cases can be proven as imminent and knowingly created, debate should naturally “shift towards the neces- sity of intervention by government and industry officials” [102]. Attribution and climate-health science. Litigation rests fundamentally upon the ability of the plaintiff to link the accused actions to evidence-backed consequences. Climate attribu- tion science offers the ability to prove causation and is now viewed as a central ingredient for success. Contemporary use of extreme event modelling and the accessibility of this data to the PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 19 / 31

court plays a large role in determining the “attributable risk” of scrutinized actions in climate litigation [103]. With climate-health science currently increasing in strength and credibility, data-backed argumentation offers powerful leverage in future health-centred climate litigation. For exam- ple, in Neubauer et al. v Germany (Table 1, case 4), plaintiffs cite IPCC data showing the risk of death, injury, and damage to health in low-lying coastal areas vulnerable to storm surges, coastal flooding, and sea level rise. Plaintiffs cited robust evidence of the link between rising allergies and lengthening pollen seasons, between respiratory diseases and both ragweed blooms and flood-induced indoor mould growth, and storm/flood disasters and psychological trauma. This is supported by the conclusion drawn by McCormick et al. (2018) that “the strength of the scientific evidence mustered to support litigants’ challenges is likely to be an important determinant of case outcomes” [100]. Cases reviewed by McCormick et al. [100] revealed that climate science was only occasion- ally a central part of the court decisions. This indicates the existence of competing factors which weigh into the decision-making on legal outcomes. Thus, to strengthen the relative weight placed on scientific evidence in legal decision-making on climate litigation, an argu- ment can be made that emphasis should be put on the most scientifically sound, and socially, politically, and economically salient points, backed by expert testimony and robustly generated

syntheses of the literature. An additional requirement may be for evidence to show that health risks are imminent, since it has been shown that the narrative of climate risks being distant in space and time dilutes the urgency to act now or the credibility of climate risk allegations [102]. With regards to leveraging the insights, research, and testimony of public health experts in climate litigation, it is worth noting the possibility of COVID-19 having opened a policy win- dow for such action. Undoubtedly, COVID-19 has raised the profile of public health expertise and the value of epidemiology. Thus, public health expertise may be accorded rightful recogni- tion in courts of law in a post-COVID-19 era, something which can and should be exploited in upcoming climate litigation. Economic incentives as a barrier to or incentive for public health Financial liability and public health. The case law brings forward economic and finan- cial considerations, presenting as either incentives or barriers to ‘adaptation and mitigation’, accompanied by liability for market actors. This can give rise to climate laws and policies, that are concerned with “mitigating, adapting and regulating” industrial activity which causes cli- mate change. Whilst the unmitigated consequences from climate change are catastrophic, a hesitance persists in some courts to “overhaul industries”, as indicated by the Juliana case [67]. Despite pledges by many corporations to reach ‘net zero’ emissions by 2050, there is not yet any con-

tractual or legal obligation to enforce this. The agreement at COP26 to establish rules for a global voluntary carbon market also raises complex issues about the ethics of carbon offsetting, and whether access to finance comes with a human rights and health cost for local and indige- nous communities in low-income countries [104]. The evolving link between financial systems, climate change, and the public health cost, is an important indicator in climate litigation [105]. It is extensively documented in the publica- tions of UNEP(FI) [106] where “climate change is referred to by leading economists as the greatest market failure in human history”. The 2020 EU taxonomy regulation on sustainable finance, is framed along the same lines as ‘climate law and policy’, namely objectives of Climate change mitigation, Climate change adaptation, Sustainable use and protection of water and PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 20 / 31

marine resources, Transition to a circular economy, Pollution prevention and control, and Pro- tection and restoration of biodiversity and ecosystems [107] (other jurisdictions such as China have a similar, yet distinct objectives). In the case of Milieudefensie et al. v Royal Dutch Shell (Table 1, case 9), litigants sought to extend the ruling of Urgenda to private companies. Shell is the parent company of many subsidiaries and has a principal place of business in the Hague, Netherlands. According to the summons, “the financial incentive for Shell to continue its fossil business model developed since 1890 is enormous, which is why it hampers the energy transition, and every year contin- ues to invest dozens of billions to secure the future of the fossil industry for much of this cen- tury”. Milieudefensie campaigns for “climate-friendly banking” and believes “private banks and public asset managers are the ideal partners in that respect”. In the ruling against Shell the court stated that although “RDS cannot solve this global problem on its own. However, this does not absolve RDS of its individual partial responsibility to do its part regarding the emis- sions of the Shell group, which it can control and influence”. The centrality of financial capital in global economies embeds financial institutions within the broader climate law and mitigation landscape. Financial investment is a powerful influen- cer on industrial and economic activities serving as an enabler, through incentives, or as a bar-

rier. These organizations offer another avenue for communities to ensure their sentiments are reflected. With regards to financial institutions, several cases illustrate this indicator of finan- cial liability in climate change lawsuits, in which the strategy of litigation has been referred to as “investor activism” [108]. In McVeigh v Rest [109], the respondent sought information from his investment fund, about any actions the respondent was taking, regarding the financial risk posed to his investment by cli- mate change. The court decided that funds have a duty to disclose information that allow the investor to make an informed decision about the investment in relation to such climate risk. Con- sidering the shifting values as citizens on all continents witness climate catastrophes, and the emergence of global youth movements, consumer and social preferences are changing in favor of the environment, health, and well-being. Consequentially, banks, insurers and investment funds face increasing risks of litigation if their activities are not compliant with climate frameworks. In JAM v International Finance Corp [110] (IFC), a group of Indian villagers brought a case against IFC, the investment arm of the World Bank, before the US Supreme Court, because it had financed the construction of a coal fired plant in India, which polluted the surrounding area. Prior to this case, the IFC held immunity from such prosecutions, in the same manner enjoyed by foreign governments. This ruling overturned the IFC’s immunity from liability for

its investments. Because the case involved the World Bank, such a ruling exemplifies how financial entities can be liable in law for financing harm to the environment and public health. Cases of climate litigation reinforce the need for a globally coordinated approach to climate law, public health, and economics. The World Bank has offered categories for Environmental and Social Investing (ESG) including negative screening, best in class, impact investing, ESG integration, and responsible ownership [111]. All of this relies upon data provided by sover- eign countries. The challenges of climate adaptation and mitigation have been translated into a new economics. This must be fully embedded in all legal systems, before massive public health devastation ensues [42]. Despite 29 of the largest 30 financial institutions having set 2050 cli- mate goals, all 30 institutions remain committed to short terms actions, which oppose emerg- ing sustainable finance policy, and have cumulatively enabled at least $740 billion in primary financing to the fossil fuel production value chain in 2020 and 2021 [112]. It remains likely that the financial sector will continue to enable real-economy activities misaligned with 1.5˚C climate scenarios as long as they remain legally and economically viable in the short term [112]. PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 21 / 31

Climate litigation against ‘carbon majors’ due to public health impact. Litigating against corporations so that they bear the liability for harm to public health is another means to internalize the costs that these companies are currently externalizing. In 2020, a series of cases [113–116] were brought by US states against oil companies, using arguments similar to those used to curtail the tobacco industry for its devastating impact on public health [117]. In an ongoing case, Washington DC (AC Racine v Exxon/BP/Shell/Chev- ron) [118], the defendants are accused of “systematically and intentionally misleading the pub- lic about the central role their products play in causing climate change, one of the greatest threats facing humanity”, including through coordinating campaigns of disinformation. In City and County of Honolulu v Sunoco oil [119], the claim is that not only have “Native Hawaiian cultural sites, built structures, natural resources, and infrastructure including roads, sewerage, and beach parks, and other resources been more frequently flooded and, in some cases, inundated”, but oil companies knew the climate science, and impending harm to public health since the 1950’s. The state is thus seeking financial compensation for losses, which illus- trates how the courts are asked to price the impacts of climate change. In this way market forces incentivize adaptation of corporates’ business model and capital away from harmful activity [120, 121]. The courts play a central role in deciding how quickly

new legal incentives are integrated into legal systems, and these cases may become important milestones. Prioritizing health above economics. Legal epidemiology is the study of law “as a factor in the cause, distribution, and prevention of disease and injury” [122]. The impact of tax and employment law on public health [123] has been studied. In the 65 public health cases included, there is an expectation from plaintiffs that government and economic actors will pri- oritize human health and planetary survival over economic profit. In the case of Youth Verdict v Waratah Coal, youth argue that the government has a duty of care to protect the health of its citizens. Further, in the 2020 ruling on modification to ethanol [124], the Mexican Supreme court decided an agency was restricted from raising the ethanol content in fuel, as the ‘right to a healthy environment’ must be prioritized over economic profit. Research has shown that “carbon-only” approaches to mitigating climate change that do not explicitly integrate air and water pollution and environmental justice considerations could fail to alleviate the public health harms and disproportionate burdens of fossil fuel production and use or even exacer- bate them [56]. Considering that in response to the Covid-19 crisis, many (though not all) gov- ernments acted forcefully to prevent a public health emergency, including by deprioritizing the economy, it is likely that the expectation of prioritizing planetary health will only rise. With global fiscal support for the pandemic already amounting to a sheer $9 trillion by April

2020 [125], the Covid-19 crisis also further demonstrated the financial capacity for large-scale investment when imminent threats arise. At a minimum, to prevent a climate-health crisis, there is an expectation for the risk to be fully priced into the financial markets. Yet, eco-centric laws can go further. The concept of ecocide is a way of protecting the environment and health, which goes beyond civil liability, and makes it a crime to harm nature [126]. As highlighted in the 2020 status report on global climate litigation, there is mounting evidence of an increased appetite by the general public to crack down on corporate irresponsibility, requiring greater climate disclosure and an end to “corporate greenwashing” on the subject of climate and the energy transition. Recommendations As the climate-health crisis further intensifies in the coming years, the expansion of legal chan- nels for halting and prosecuting climate-destructive, health-threatening operations and PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 22 / 31

anthropogenic activities will prove essential. To ensure that future legal action on environmen- tal issues serves public health objectives, two conditions must be present: 1) public health- framed argumentation must feature strongly in allegations of wrongdoing and 2) courts are receptive to public health arguments and accord their deserved weight in the holistic assess- ment of cases and determination of legal outcomes. To promote such conditions, we issue the following recommendations to potential plaintiffs, public health stakeholders, climate activists, climate-engaged investors, NGOs, and other institutions: 1. Initiate or support legal cases in every jurisdiction, backed by public health science, to put pressure on governments and corporations, to upscale their commitment to de-carbonize, and uphold their duty of care responsibilities. 2. Advocate for the democratic passage of eco-centric laws and climate liability incentives, both national and international, which feature health as a primary objective; this can include the passage of an International Law of Ecocide. And interpret existing statutory requirements in a public health frame to provide a clear legal path for the pursuit of liti- gation according to internationally adopted legal principles of human rights and public health. 3. Mobilize additional funds for climate-health research to quantify impacts, assess attribution and assess adaptation strategies as alternative options to provide the necessary scientific evi- dence demonstrating the indisputable, ubiquitous, tangible, existing and imminent, and

clearly anthropogenically-driven threats to human health 4. Promote greater awareness of climate-health links amongst public interest groups by incor- porating dedicated climate-health curricula into higher education. Legal epidemiology, as the study of law in the cause, distribution and prevention of disease and injury, must be extended to the field of climate law to ensure legislation is instrumentalized most effectively for public health protection and promotion 5. Develop national and international environmental health law expert panels including strong public health expertise to provide expert testimony and briefings during court hear- ings and consult with judges on the sound interpretation and application of climate-attribu- tion science Limitations We recognize the limitations inherent in drawing conclusions based on a review of western- centric sources, which may well have failed to capture the full scope of litigation. Most impor- tantly, legal cases from certain regions and countries are not all included in the databases searched. While nine translated climate laws and policies are reported from China, including the “National Plan for Tackling Climate Change 2014–2020”, no case litigation is reported, even though there is indication such cases have taken place in China. Similarly, three climate laws and policies are reported from Saudi Arabia including the “Saudi Arabia Vision 2030” and 26 from Vietnam, yet no cases are reported for either country. Aside from the countries and regions for which case laws have not been included, there

may also have been criminal and penal charges (i.e. criminal litigation) not captured given the Western-centric focus on civil litigation within these databases. The sources used are also both English language databases, respectively from the United States and the United Kingdom. The Common Law system underpinning the reported cases also has roots in the British Empire [127], introducing an inevitable bias in the legal scope of cases captured in this review. PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 23 / 31

Finally, we recognize that our “case definition” of public health-linked cases may be too narrow to capture all those cases which truly express a concern for human health as one of the many issues at stake in climate litigation. Indeed, we observed a far greater number of cases which alluded to aspects of public health under threat without explicitly using the word “health”. The relative importance of these cases should not be overlooked, for they undoubt- edly represent a shifting mindset towards climate change, with the perceived threats to human health taking a more central role. Climate Litigation is restricted by barriers preventing access to justice, including access to legal knowledge. We did not use subscription case law sources, including Westlaw, Thompson Reuters, and Lexis Nexus, RELX, as these databases are not open access and a costly subscrip- tion can limit access for prospective climate litigants especially in low-income countries. Per- haps, restricted access to legal sources exacerbates the problem of climate injustice, as it is a reality that those disproportionately impacted by climate change have least access to justice. We have not examined questions of jurisprudence, which extend into theoretical questions such as what is law? Yet, climate Science can undermine the legitimacy of legal systems, as if laws are not aligned with science should they be valid law. We researched the field of climate law through the lens of legal cultures, which have caused climate change, and so the western, anthropocentric, legal culture is reflected in its research.

Conclusion Despite its limitations, this relatively comprehensive review of climate litigation over the past three decades has revealed notable developments in the legal field of environmental gover- nance, many of which are encouraging from public health, human rights, and eco-centric per- spectives. The field is undergoing a rapid transition. Yet reticence persists. Defence teams can no longer argue against the validity of the science, or ignorance of the link between anthropogenic climate disruption and human health harm. In the context of climate health emergency, it is evident that amplification of decarbonisation efforts is urgently required. Litigation offers a powerful tool to drive multi- sector transition. Given the shortcomings that remain in the widespread use and acceptance of public health claims in legal argumentation used for litigation, we advise that laws and legal incentives are created, which position public health as a central focus. In the interests of future generations, we argue for more funding to be mobilized towards climate-health evidence and further develop this research as a scientific discipline, the promotion of greater public and industry awareness of climate-health links to support more widespread utilization of public health claims in allegations of wrongdoing, and that a legal panel of climate-health experts be devised which can be called upon by plaintiffs to provide expert testimony and deliver credible yet compelling research briefings during court hearings.

We advocate for the establishment of multi-lateral body, with legally binding power, to access breaches of existing law, identify laws that amplify disproportionate health impacts upon specific communities, responds to systemic racism, corruption, and inequities within legal systems, is aligned with the Hague to bring criminal charges against nations and corpora- tions, and works to develop real legal incentives to ensure planetary and human safety. Considering the impacts of climate change, we must ensure that health risks are fully inte- grated into the economic cost should companies seek to avoid liability for climate risks. Should this recommendation be adopted, we are confident we will see further developments in the field of litigation where public health arguments play a key role in mobilizing legislative action. As the risk of harm to public health is integrated into the economy, through legal liability, this can incentivize a well-being/health-based economy. This will be a win for not only the PLOS ONE Public health as a legal tool in climate litigation PLOS ONE | https://doi.org/10.1371/journal.pone.0268633 June 15, 2022 24 / 31

plaintiffs pursuing litigation, but also for the whole of humanity whose health and future sur- vival is under dire threat by the climate crisis. Supporting information S1 Data. (XLSX) Acknowledgments The authors would like to thank the World Federation of Public Health Associations Environ- mental Health Working Group for supporting this research through the provision of expert guidance in the development and finalization of this report. Two notable members, Peter Orris and Peter Tait, provided regular input throughout the development of this report, and are thanked for their respective contributions. Author Contributions Conceptualization: Narayan Toolan. Data curation: Narayan Toolan. Formal analysis: Narayan Toolan, Hannah Marcus, Elizabeth G. Hanna, Chadia Wannous. Investigation: Narayan Toolan, Hannah Marcus. Methodology: Narayan Toolan, Hannah Marcus, Elizabeth G. Hanna, Chadia Wannous. Project administration: Narayan Toolan, Elizabeth G. Hanna, Chadia Wannous. Resources: Narayan Toolan, Elizabeth G. Hanna, Chadia Wannous. Software: Narayan Toolan. Supervision: Elizabeth G. Hanna, Chadia Wannous. Validation: Narayan Toolan, Hannah Marcus, Elizabeth G. Hanna, Chadia Wannous. Visualization: Narayan Toolan, Hannah Marcus. Writing – original draft: Narayan Toolan, Hannah Marcus. Writing – review & editing: Narayan Toolan, Hannah Marcus, Elizabeth G. Hanna, Chadia Wannous. References 1. Setzer J, Byrnes R. Global trends in climate change litigation: 2021 snapshot. London: The Grantham

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