In its recent decision addressing whether the atmosphere and climate change are covered by the public trust doctrine, the Arizona Court of Appeals cited an article by Robin Kundis Craig, Professor of Law at the University of Utah S.J. Quinney College of law, published in the Ecology Law Quarterly produced by the UC Berkeley School of Law.
Although the case was dismissed on procedural grounds, the court didn’t rule out the possibility that the doctrine could extend so far. Butler ex rel. Peshlakai v. Brewer, 2013 WL 1091209, at *3 (March 14, 2013).