Summary:
On 11 March 2024, a representative of the community of San Bartolo Coyotepec in Mexico’s State of Oaxaca filed an amparo petition with the Ninth District Court of the State of Oaxaca, arguing that the human right to a healthy environment had been violated because municipal, state, and federal authorities had failed to protect Benito Juárez National Park and the corresponding Ecological Reserve and Protected Natural Area. On 20 March 2025, the case was rejected by the Ninth District Court given the failure to demonstrate a concrete, direct, and imminent harm resulting from the alleged failure to protect the designated areas.
The applicant appealed, arguing that the first instance judge had failed to reason his decision, had shifted the burden of proof to his detriment, and had improperly evaluated the evidence concerning the progressive deterioration of the protected natural areas in question.
On 20 October 2025, the Supreme Court of Justice of Mexico accepted the case for review. On 24 February 2026, the Plenary Session of the Supreme Court of Justice ordered that the case be remanded to the Ninth District Court to amend the ruling that denied constitutional protection, gather evidence and determine whether the applicant’s human right to a healthy environment had been violated. It established that, pursuant to Article 4 of the Mexican Constitution, which enshrines the right to a suitable environment, any person who inhabits or uses an ecosystem and benefits from its environmental services may go to court to demand its protection, without needing to prove direct individual harm.
In doing so, the Court explicitly linked the case to climate change. It noted the interconnectedness of the three aspects of the ‘triple planetary crisis’ (climate change, biodiversity loss and pollution), and held that none of these aspects can be treated in isolation from each other. It noted the applicant’s framing of the territory in question as a carbon sink. It also extensively cited the 2025 advisory opinions on climate change of the International Court of Justice and the Inter-American Court of Human Rights (IACtHR). It particularly emphasized the IACtHR’s finding that “urged States to maximize the scope of protection of the right to the environment, recognizing that this right protects not only individuals, but also the components of the environment—such as forests, rivers, seas, and other ecosystems—as autonomous legal interests, even in the absence of certainty or immediate evidence of a direct risk to specific individuals” (para. 43). In doing so, it noted that according to the IACtHR climate change poses an imminent risk to life, health, food security, and the balance of ecosystems on a global scale (para. 42), as well as extensively citing the ICJ’s discussion of the right to a healthy environment in its climate advisory opinion (para. 35).
With this decision, the Court reaffirmed the “adjacent environment” doctrine in environmental matters. This means that individuals who live in or use the area of influence of an ecosystem and receive its environmental benefits may file an amparo petition, even if they do not live immediately adjacent to the Protected Natural Area. Furthermore, the Court noted that environmental protection must be analyzed in accordance with the precautionary principle, meaning that the absence of scientific certainty regarding the benefits of the ecosystem in question cannot be used to deny its protection or to disregard the relationship between people and the natural environment.
Suggested citation:
Supreme Court of Justice of Mexico, Community Representative of San Bartolo Coyotepec v. State of Oaxaca, direct amparo petition no. 6714/2025, 24 February 2026.
Amparo ruling:
Last updated:
24 June 2026.