Duke Power Co. v. Carolina Environmental Study Group

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Duke Power Co. v. Carolina Environmental Study Group, 438 U.S. 59 (1978), was a case in which the United States Supreme Court overturned the United States District Court for the Western District of North Carolina's decision that the Price Anderson Act violated equal protection by treating victims of nuclear accidents differently from the victims of other industrial accidents.

Background

Several groups filed suit in the United States District Court for the Western District of North Carolina against the Nuclear Regulatory Commission, regarding the Price Anderson Act. The suit challenged it on two grounds; it violated the Fifth Amendment because it did not ensure adequate compensation for victims of accidents, and it violated the Fourteenth Amendment because it treated nuclear accidents differently from other accidents.

Decision

The Court found that the differential treatments of industrial victims did not constitute a violation of equal protection, based on the reasons Congress gave for liability limitations: "There is no equal protection violation, since the general rationality of the Act's liability limitation, particularly with reference to the congressional purpose of encouraging private participation in the exploitation of nuclear energy, is ample justification for the difference in treatment between those injured in nuclear accidents and those whose injuries are derived from other causes." The court summarised the circumstances leading up to the act: The court also concluded:

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