Harmon Industries v. Browner
United States Court of Appeals for the Eighth Circuit
191 F.3d 894 (1999)
After learning of a long-standing practice of disposing volatile solvents behind its circuit board manufacturing plant, executives with Harmon Industries (plaintiff) self-disclosed the issue to the Missouri Department of Natural Resources (MDNR). Thereafter, Harmon and MDNR worked together to implement a cleanup plan for the site. At the same time, the Environmental Protection Agency (EPA) investigated the Harmon disposal site and sought over $2.3 million in penalties under the Resource Conservation and Recovery Act (RCRA). After a Missouri state court judge approved the agreement between Harmon and MDNR, Harmon litigated the RCRA claim before an Administrative Law Judge (ALJ). The ALJ held for the EPA and assessed a $586,716 penalty against Harmon. The decision was affirmed by an Environmental Appeals Board. Subsequently, Harmon filed suit in federal court against Carol Browner, in her official capacity as Administrator of the Environmental Protection Agency (EPA) (defendant) and others challenging EPA’s action. The district court granted summary judgment in favor of Harmon and held that EPA’s decision to impose civil penalties violated the Resource Conservation and Recovery Act. EPA appealed.
Rule of Law
Holding and Reasoning (Hansen, J.)
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