 That ruling was reversed by a unanimous Supreme Court in "Direct Marketing Ass'n v. Brohl" (2015).In 2016, the Tenth Circuit panel rejected the challenger's dormant commerce clause claim, with Gorsuch writing a concurrence.In "Energy and Environmental Legal Institute v. Joshua Epel" (2015), Gorsuch held that Colorado's mandates for renewable energy did not violate the commerce clause by putting out-of-state coal companies at a disadvantage.