Chris Thomas

Executive Committee | Membership Committee Co-Chair | Fellow since 2016

Hollandhart

Partner

(602) 507-9704 (work)

(602) 316-9334 (mobile)

[email protected]

Phoenix, Arizona

Region 9 serving AZ, CA, HI, NV, and certain territories

ACOEL Committees

Communications Committee Education Committee Membership Committee

Environmental Law Topic

Administrative Law Energy Environmental Enforcement Environmental Impact Review Resource Extraction Superfund

Birth, School, Work, Death

Degrees

J.D., Iowa, 1985.
B.A., Drake, 1982

Admissions

Arizona

Court Admissions

Arizona
District of Arizona
Ninth & Tenth Circuits
U.S. Supreme Court

Illustrative Projects

Advising Resolution Copper Mining, LLC, a joint venture between Rio Tinto and BHP, on environmental regulatory issues pertaining to its proposed copper mine project near Superior, Arizona.
Advising South32 Hermosa Inc. on environmental regulatory issues pertaining to its lead-zinc-manganese exploration project southeast of Patagonia, Arizona.
Helping developers of wind, photovoltaic solar, battery storage, and geothermal facilities obtain necessary permits and approvals from federal and state regulators.
Advising hedge funds and other investors on potential environmental liabilities associated with investments in mines, power plants, water and wastewater utilities, and real estate developments.

Citations of Major Published Cases

Seven County Infrastructure Coalition v. Eagle County, Colorado, 602 U.S. -- (2025) (counsel for amicus American Exploration and Mining Association et al in case addressing judicial deference owed under NEPA to executive branch agencies No. 23-975 (U.S. 2024).
Sackett v. Environmental Protection Agency, 598 U.S. 651 (2023) (counsel for amici American Exploration and Mining Association et al in leading WOTUS case).
Apache Stronghold v. United States, 101 F. 4th 1036 (9th 1036) (en banc), cert. denied, 145 S. Ct. 1480 (2025) (proposed land exchange to facilitate copper mine did not violate Religious Freedom Restoration Act).
Gallagher & Kennedy, P.A. v. City of Phoenix, 2024 U.S. App. 22106 (9th Cir. Aug. 30, 2024) (District Court properly dismissed CERCLA claims incurred by subcontractors whom law firm that retained them had no obligation to reimburse).
State of Arizona v. Ashton, et al., 761 F.3d 1005 (9th Cir. 2014), denied, 577 U.S. 913 (2015) (deference owed by courts to state agency-negotiation CERCLA settlements).
Solutia v. McWane, et al., 672 F.3d 1230 (11th Cir. 2012), denied, 568 U.S. 942 (2012) (EPA administrative order extinguished pending contribution claims incurred under prior consent decree).
Evans v. Walter Industries, 449 F. 3d 1159 (11th Cir. 2006) (industrial defendants properly removed toxic tort case under then-new provisions of Class Action Fairness Act).
San Carlos Apache Tribe v. State, 550 P.3d 1096 (Ariz. 2024) (new, integrated mine shaft did not constitute or create a “new source” under Clean Water Act).
Roosevelt Irrigation District v. Salt River Project, et al., 222 F. Supp. 3d 898 (D. Ariz. 2017) (plaintiff using contingent-fee lawyers did not incur CERCLA response costs).
City of Phoenix v. Garbage Service Co., 816 F. Supp. 564 (D. Ariz. 1993), and 827 F. Supp. 600 (D. Ariz. 1993) (bank as testamentary trustee was personally liable as CERCLA owner under case that prompted congressional adoption of 42 USC §9607(n).