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1 Published in Trends, Volume 40, Number 5, May/June 2009. © 2009 by the American Bar Association. Reproduced with permission. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or stored in an electronic database or retrieval system without the express written consent of the American Bar Association Two years after the U.S. Supreme Court remanded Massachusetts v. EPA, 549 U.S. 497 (2007), to the Environmental Protection...