L. Claire Hansen and Catherina D. Narigon Quoted in Packaging Dive Article “California EPR lawsuit escalates as forthcoming Oregon ruling looms”
On August 21, 2026, comments by L. Claire Hansen and Catherina D. Narigon were featured in Packaging Dive’s article discussing legal challenges that are underway to block SB 54 enforcement.
“The subsequent briefing shows that the parties disagree not only over whether the exemption is discriminatory, but also over whether NAW has standing to challenge it and what remedy would be appropriate if the court identifies a constitutional problem,” said L. Claire Hansen and Catherina D. Narigon, associates at Bergeson & Campbell, in an emailed analysis.
NAW in part argued that “the statutory text itself treats Oregon and out-of-state public bodies differently and that no evidence of real-world discriminatory effects is necessary to establish facial discrimination,” the B&C attorneys explained. “NAW also argues that its members have standing because exempting additional entities from the RMA’s funding base increases the costs borne by non-exempt producers.”
Ultimately, the judge considered NAW’s asserted economic injury to be speculative “and argues that any defect in this particular exemption would not justify invalidating the broader regulatory program,” they said.