TDY Holdings, LLC v. United States

摘要

Federal district court abused its discretion in allocating 100 percent of cleanup costs to manufacturer and zero percent to federal government in Comprehensive Environmental Response, Compensation, and Liability Act contribution action brought by manufacturer against government for share of contaminated site cleanup costs, even though court did not misunderstand strict liability standard of CERCLA liability or abuse its discretion in considering government role as owner and not operator of site, because: (1) encumbering military contractor with 100 percent of CERCLA cleanup costs incurred during war effort production was departure from previous case law, (2) government required manufacturer to use two chemicals that contaminated site, (3) court acknowledged evolving understanding of contamination caused at site and manufacturer's prompt adoption of practices to reduce releases of known hazardous substances, and (4) court did not adequately consider parties' lengthy course of dealings in which government agreed to share in cleanup costs. For the foregoing reasons, we affirm the Court of Appeals as to Miller's state-law damages claims; however, we reverse the Court of Appeals insofar as it held that Miller's claim for injunctive relief could go forward. Therefore, we remand this case to Jefferson Circuit Court for further proceedings consistent with this opinion.