Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

settlementliabilitystatuteclean water act
settlementliabilitystatute

Related Cases

Block v. California Physicians’ Service, 244 Cal.App.2d 266, 53 Cal.Rptr. 51
View Case »
Defenders of Wildlife v. Administrator, E.P.A., 882 F.2d 1294, 30 ERC 1460, 19 Envtl. L. Rep. 21,440
View Case »
Alaska Wilderness League v. Jewell, 788 F.3d 1212, 80 ERC 2036, 15 Cal. Daily Op. Serv. 5944, 2015 Daily Journal D.A.R. 6421
View Case »
Center for Biological Diversity v. United States Forest Service, 80 F.4th 943, 23 Cal. Daily Op. Serv. 8847, 2023 Daily Journal D.A.R. 9084
View Case »
United States v. Dico, Inc., Not Reported in Fed. Supp., 2017 WL 9049852
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Territory of Guam v. United States, 593 U.S. 310, 141 S.Ct. 1608, 209 L.Ed.2d 691, 21 Cal. Daily Op. Serv. 4614, 2021 Daily Journal D.A.R. 4960, 28 Fla. L. Weekly Fed. S 807

Facts

Guam and the United States have a long-standing dispute over the Ordot Dump, a landfill on Guam that was used by both parties for waste disposal. In 2004, Guam entered into a consent decree with the EPA to address violations of the Clean Water Act, which required Guam to pay penalties and remediate the dump. Years later, Guam sought to recover costs under CERCLA, claiming that the United States' actions at the dump exposed it to liability. However, the D.C. Circuit found that Guam's contribution claim was time-barred due to the earlier consent decree.

Guam and the United States have a long-standing dispute over the Ordot Dump, a landfill on Guam that was used by both parties for waste disposal.

Issue

Does a settlement of environmental liabilities under a statute other than CERCLA give rise to a CERCLA contribution action?

Does a settlement of environmental liabilities under a statute other than CERCLA give rise to a CERCLA contribution action?

Rule

A settlement of environmental liabilities must resolve a CERCLA-specific liability to give rise to a contribution action under § 113(f)(3)(B) of CERCLA.

A settlement of environmental liabilities must resolve a CERCLA-specific liability to give rise to a contribution action under § 113(f)(3)(B) of CERCLA.

Analysis

The Supreme Court analyzed the text and structure of § 113(f) of CERCLA, concluding that the provisions governing contribution claims are designed to address only CERCLA-specific liabilities. The Court emphasized that the phrase 'resolved its liability' implies a finality that cannot exist if a party remains vulnerable to a CERCLA suit. Therefore, a contribution claim can only arise from a settlement that specifically addresses CERCLA liabilities, not those under other environmental statutes.

The Supreme Court analyzed the text and structure of § 113(f) of CERCLA, concluding that the provisions governing contribution claims are designed to address only CERCLA-specific liabilities.

Conclusion

The Supreme Court reversed the D.C. Circuit's decision and remanded the case, holding that Guam's prior consent decree did not give rise to a CERCLA contribution claim because it did not resolve a CERCLA-specific liability.

The Supreme Court reversed the D.C. Circuit's decision and remanded the case, holding that Guam's prior consent decree did not give rise to a CERCLA contribution claim because it did not resolve a CERCLA-specific liability.

Who won?

The United States prevailed in the case because the Supreme Court determined that Guam's contribution claim was not valid under CERCLA due to the nature of the prior consent decree.

The United States prevailed in the case because the Supreme Court determined that Guam's contribution claim was not valid under CERCLA due to the nature of the prior consent decree.

You must be