Overview

Karma leverages her extensive permitting and litigation experience under the Clean Water Act (CWA), the National Environmental Policy Act (NEPA), and the Endangered Species Act (ESA) to help clients navigate complex environmental challenges. She has been at the forefront of many precedent-setting cases in the natural resources sector, litigating high profile, multi-party cases across the country in federal and state courts.

She represents clients across industries, including national trade associations, pipelines, electric utilities, solid waste companies, developers, and water agencies. Karma’s practice focuses on a wide range of environmental and administrative law issues, with an emphasis on natural resources litigation and regulatory compliance, and on the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Karma is widely regarded for her ability to negotiate settlements with the Department of Justice in controversial matters, and clients value her ability to work collaboratively with industry coalitions, states, the federal government and technical consultants.

Karma represents cross-industry coalitions on a wide range of key issues, such as the Nationwide Permits (NWPs) and the scope of federally regulated “waters of the United States” (WOTUS) under the CWA, the criteria for designation of critical habitat and listing decisions under the ESA, and CEQ’s NEPA rules. In addition, Karma has significant experience drafting comments on administrative rulemakings and advising clients and their technical consultants on the preparation of NEPA, ESA, and CWA permitting documents, including keeping clients apprised of continually evolving policy and regulatory clarifications.

A significant portion of Karma’s practice involves managing the environmental aspects of complex business transactions and major development projects. Karma draws upon her extensive experience in both litigation and transactional matters to balance clients’ business objectives with the practical aspects of the case.

Karma speaks regularly on a wide variety of topics, including administrative and environmental law, and has undertaken significant pro bono work, representing detainees at Guantánamo Bay in habeas corpus proceedings and numerous asylum applicants before the Department of Homeland Security. She served as a member of the firm’s pro bono committee and charitable giving committee and received the firm’s E. Randolph Williams Award for Outstanding Pro Bono Service.

Karma was an adjunct professor at The George Washington University Law School from 2007 to 2009. Before joining the firm, she was an attorney-advisor in the Solicitor’s Honors Program at the US Department of the Interior, Office of the Solicitor, and a judicial law clerk to the Honorable Francis M. Allegra of the US Court of Federal Claims, Washington, DC.

Experience

  • Represent coalition of trade associations in federal litigation challenging the US Army Corps of Engineers’ (Corps) reissuance of Nationwide Permit 12, successfully obtaining a Supreme Court stay of a district court order imposing a nationwide injunction.
  • Counsel to energy company in successful defense of challenge to a National Park Service authorization and related ESA and NEPA analyses.
  • Counsel to coalition of energy utility companies in litigation before the US Court of Appeals for the Sixth Circuit and the Supreme Court challenging the Corps’ and EPA’s 2015 Rule defining WOTUS.
  • Represent coalition of national agricultural and industry associations in litigation challenging rules issued by the Environmental Protection Agency (EPA) and the Corps under CWA section 404 and the Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) under the ESA.
  • Manage environmental aspects of complex business transactions, including identifying environmental compliance requirements and environmental risks and developing creative approaches to manage such issues to ensure they do not impede the transaction.
  • Regularly assist clients on issues relating to Corps jurisdictional determinations and the use of general and individual CWA permits, including administrative appeals under the Corps regulations and defense of permits and NEPA and ESA analyses in federal district and appellate courts.
  • Prepare cross-industry amicus briefs on influential CWA and ESA cases before the US Supreme Court and US Courts of Appeals.
  • Negotiate settlements of litigation arising under section 404 of the CWA and challenges to ESA regulations, and advise clients on compliance with complex consent decrees.
  • Prepare comments on EPA and Corps CWA rulemakings and FWS and NMFS ESA rulemakings.
  • Advise natural gas pipeline company, electric utility, and industry groups regarding compliance counseling and permitting under Rivers and Harbors Act section 408.
  • Counsel to major waste hauling company in CERCLA and natural resource damages litigation, allocation, and alternative dispute resolution proceedings involving hundreds of parties and state and federal agencies; evaluate technical and legal issues relating to site remediation; advise on evolving legal issues and potential liability associated with the disposal of emerging contaminants; and investigate other potentially responsible parties.

Accolades

Honors & Recognitions

  • Recognized as 2021 Environmental Group of the Year, Law360, January 2022
  • Selected as a Super Lawyer for Environmental, The Washington Post Magazine, 2013-2024
  • Recommended for Environment: Litigation, Legal 500 United States, 2021
  • 2021 and 2017 Chambers USA Environment Law Firm of the Year
  • Named among Law360’s Environmental Rising Stars, 2012

Affiliations

Professional

  • Member, American Bar Association Section on Environment, Energy, and Resources
  • Member, Legal Action Committee, National Association of Home Builders, 2012–2022
  • Member, Legal Affairs Committee, National Association of Clean Water Agencies, 2014–2022
  • Vice Chair, Endangered Species Committee, American Bar Association Section on Environment, Energy, and Resources, 2008–2010
  • Adjunct Professor, The George Washington University Law School, 2007–2009

Civic

  • Member of Firm's Pro Bono Committee.
  • Represent detainees at Guantánamo Bay in habeas corpus proceedings and numerous asylum applicants before the Department of Homeland Security.
  • Recipient of the E. Randolph Williams Award for Outstanding Pro Bono Service, 2003-08.

Insights

Events & Speaking Engagements

  • February 9, 2023
    Event
    Speaker
    The 2023 Waters of the United States Rule: What Co-ops Need to Know, National Rural Electric Cooperatives Association Webinar
  • December 1, 2022
    Event
    Moderator
    “Regulating Through Administration Transitions: Can There Be Certainty?,” American Bar Association, Administrative Law Conference
  • September 13, 2022; May 2, 2022; October 4, 2021; April 26, 2021; December 2, 2020; April 30, 2019; October 24, 2018; March 29, 2017
    Event
    Presenter
    Waters of the U.S. and Nationwide Permit Regulatory and Litigation Updates, American Gas Association Environmental Regulatory Action Committee
  • April 27, 2022; May 12, 2020
    Event
    Speaker
    Waters of the U.S., NEPA, and Nationwide Permit Updates, Association of Oil Pipe Lines Legal Committee
  • November 6, 2020
    Event
    Speaker
    Major Undecided Environmental Issues in 2021, National Rural Electric Cooperative Association, Generation & Transmission Legal Seminar
  • May 28, 2020
    Event
    Presenter
    Monarch Butterfly Candidate Conservation Agreement with Assurances, National Rural Electric Cooperative Association
  • April 28, 2020
    Event
    Presenter
    Natural Resources Regulatory Developments in the Time of COVID-19, Ad-Hoc Natural Resource Management Group

Publications

Blog Posts

News

Education

JD, The George Washington University Law School, with high honors, articles editor, The George Washington International Law Review; Order of the Coif, 2000

BA, Northwestern University, 1996

Admissions

District of Columbia

Maryland

Government Service

Solicitor’s Honors Program, US Department of the Interior

Clerkships

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