On March 17, 2015, a Massachusetts trial court granted a motion to dismiss filed by entities responsible for overseeing and administering Harvard University's endowment in an action brought by the Harvard Climate Justice Coalition and seven Harvard University students seeking to enjoin Harvard from holding any direct or indirect investments in fossil fuel companies. The plaintiffs brought the lawsuit in November 2014 and asserted two counts against Harvard, one for mismanagement of charitable funds and a second for intentional investment in abnormally dangerous activities. The plaintiffs alleged, among other things, that they had standing under Massachusetts law to "enforce the lawful management" of Harvard's endowment because they had interests that were personal, specific, and existed apart from any broader community interests.

In granting the defendants' motion to dismiss, the court held that the plaintiffs lacked standing to sue Harvard for alleged mismanagement of its charitable assets because the plaintiffs' status as Harvard students did "not endow them with personal rights specific to them that would give them standing to charge Harvard with mismanagement of its charitable assets" and that allegations that Harvard's investment in fossil fuel companies diminishes plaintiffs' education, chills academic freedom, and stifles confrontation of climate change on campus were insufficiently personal to the plaintiffs "to form a foundation for their standing to challenge how Harvard invests its endowment." The court likewise rejected the plaintiffs' argument that they had alleged a viable claim that Harvard had intentionally invested in abnormally dangerous activities because (i) no court in any jurisdiction had ever recognized such a tort; (ii) the plaintiffs lacked standing to assert such a claim on behalf of "Future Generations"; and (iii) allowing the plaintiffs to assert such a claim would open the door to suits from students "seeking court orders that Harvard—or any other charitable organization—take other actions to deal with the 'exceptional risks' posed by whatever danger to Future Generations those other students fear above all others."

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