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Sidley Secures Early Termination of Corporate Probation in Clean Air Act Matter for Leading Aftermarket Automotive Company
March 16, 2026
Sidley obtained the early termination of corporate probation, along with relief from all remaining unpaid criminal fines, for a leading aftermarket automotive company in United States v. Rudy’s Performance Parts, Inc., Case No. 24-cr-00336 (D.D.C. Mar. 12, 2026).
The result comes amid an important shift in federal criminal enforcement under the Clean Air Act, a cornerstone federal environmental law governing vehicle emissions. The prior prosecution involved alleged tampering with motor vehicle on-board diagnostic (“OBD”) emissions systems — the systems commonly associated with a vehicle’s “check engine” functions — under a charging theory that the U.S. Department of Justice announced in January 2026 should no longer be pursued criminally. Sidley secured the result through an unopposed motion to terminate probation and fines.
The DOJ policy change affected nearly two dozen pending criminal matters across the US$337 billion aftermarket automotive industry. Against that backdrop, the outcome for Rudy’s Performance Parts represents meaningful relief for the client and a notable development for companies across a sector that has historically faced substantial scrutiny over emissions-related products and enforcement risk.
The policy change and resulting outcome followed years of advocacy led by Sidley on Clean Air Act criminal enforcement issues, including congressional testimony by Justin Savage in September 2025 before the U.S. House of Representatives Committee on Oversight and Government Reform, Subcommittee on Federal Law Enforcement.
The decision also marks the second corporate probation modification or termination obtained by Sidley since the start of President Trump’s second term, following United States v. Austal USA, LLC, No. 24-cr-00131 (S.D. Ala. Aug. 29, 2025). Such relief is rare, with only a handful of corporate probation modifications or terminations nationwide in recent years.
The Sidley team is led by Justin Savage (Environmental, Health, and Safety), Lisa Miller (White Collar Defense and Investigations), Ike Adams (Securities Enforcement and Regulatory), and Peter Whitfield (Environmental, Health, and Safety), and includes Rose Quam-Wickham and Riley Desper (both Environmental, Health, and Safety). Sidley worked closely with co-counsel Robert M. Cary of Williams & Connolly LLP and Claire Rauscher of Womble Bond Dickinson (US) LLP.
The result comes amid an important shift in federal criminal enforcement under the Clean Air Act, a cornerstone federal environmental law governing vehicle emissions. The prior prosecution involved alleged tampering with motor vehicle on-board diagnostic (“OBD”) emissions systems — the systems commonly associated with a vehicle’s “check engine” functions — under a charging theory that the U.S. Department of Justice announced in January 2026 should no longer be pursued criminally. Sidley secured the result through an unopposed motion to terminate probation and fines.
The DOJ policy change affected nearly two dozen pending criminal matters across the US$337 billion aftermarket automotive industry. Against that backdrop, the outcome for Rudy’s Performance Parts represents meaningful relief for the client and a notable development for companies across a sector that has historically faced substantial scrutiny over emissions-related products and enforcement risk.
The policy change and resulting outcome followed years of advocacy led by Sidley on Clean Air Act criminal enforcement issues, including congressional testimony by Justin Savage in September 2025 before the U.S. House of Representatives Committee on Oversight and Government Reform, Subcommittee on Federal Law Enforcement.
The decision also marks the second corporate probation modification or termination obtained by Sidley since the start of President Trump’s second term, following United States v. Austal USA, LLC, No. 24-cr-00131 (S.D. Ala. Aug. 29, 2025). Such relief is rare, with only a handful of corporate probation modifications or terminations nationwide in recent years.
The Sidley team is led by Justin Savage (Environmental, Health, and Safety), Lisa Miller (White Collar Defense and Investigations), Ike Adams (Securities Enforcement and Regulatory), and Peter Whitfield (Environmental, Health, and Safety), and includes Rose Quam-Wickham and Riley Desper (both Environmental, Health, and Safety). Sidley worked closely with co-counsel Robert M. Cary of Williams & Connolly LLP and Claire Rauscher of Womble Bond Dickinson (US) LLP.
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