During arguments in American Elec. Power Co. v. Connecticut, Justice Scalia quipped, and asked whether a farmer could be sued for the greenhouse gases emitted from cows.

JUSTICE SCALIA: You’re — you’re lumping them all together. Suppose you lump together all the cows in the country. Would — would that allow you to sue all those farmers? I mean, don’t you have to do it defendant by defendant?

MS. UNDERWOOD: Courts sometimes

JUSTICE SCALIA: Cow by cow, or at least farm by farm?

Moo.