Atlantic Richfield Co. v. Christian

Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as the Superfund statute, to address the environmental and health consequences of large-scale industrial pollution. CERCLA was enacted (1) to promote the efficient cleanup of hazardous waste sites by developing a comprehensive response to pollution and (2) to ensure that the polluters pay for the cleanup. To accomplish these goals, CERCLA establishes procedures for identifying contaminated sites, known as Superfund sites, and for prioritizing those sites for cleanup. Pursuant to CERCLA, the Environmental Protection Agency (EPA) may either compel the responsible parties to conduct the cleanup under EPA supervision or conduct the cleanup itself and seek reimbursement from the responsible parties. In the 1970s, Atlantic Richfield Company (defendant) bought the Anaconda Copper Mining Company (Anaconda), which had operated copper smelters in Butte, Montana, contaminating an area of more than 300 square miles with lead and arsenic. After Atlantic Richfield purchased Anaconda, the contaminated area was declared a Superfund site, and cleanup efforts began pursuant to an EPA-approved plan. In 2008, a group of landowners (the landowners) (plaintiffs) within the Superfund site sued Atlantic Richfield in state court, claiming trespass, nuisance, and strict liability and proposing a restoration plan that exceeded the requirements of the EPA’s cleanup plan. Atlantic Richfield moved for summary judgment, arguing that CERCLA precluded the landowners’ claim for restoration damages. The trial court denied the motion, and Atlantic Richfield appealed to the Montana Supreme Court, arguing that CERCLA barred the landowners from seeking relief in state court. Atlantic Richfield also argued that the landowners were potentially responsible parties under CERCLA and thus were prohibited from taking remedial action without EPA approval. The Montana Supreme Court found that the landowners were not potentially responsible parties, and the United States Supreme Court granted certiorari. After determining that it had jurisdiction to hear the matter and that CERCLA did not preclude the landowners from suing Atlantic Richfield in state court, the Court considered whether the landowners were potentially responsible parties.