United States v. Bestfoods
United States Supreme Court
524 U.S. 51 (1998)
From 1957 to 1972, Ott Chemical Company (Ott) (defendant) operated a manufacturing plant in Muskegon, Michigan, which polluted the site with hazardous chemicals. In the 1960s, Ott became a wholly-owned subsidiary of CPC International, Inc. (CPC) (defendant), since renamed Bestfoods. Ott and CPC had some common directors and officers, and CPC exercised significant control over Ott’s general business operations. One CPC employee, G.R.D. Williams, played a large role in dealing with the environmental risks caused by the Muskegon plant; Williams was an employee of CPC only, and not of Ott. In the 1980s, the federal Environmental Protection Agency (plaintiff) began to remediate the property and sought contribution from owners and operators pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Ott had dissolved by this time, but CPC was one of several companies sued for contribution. The district court found that CPC was directly liable under CERCLA as an operator of a hazardous plant because of the degree of control it exercised over Ott’s operation. Among other factors, the court cited the many directors and officers common to the two companies. The appellate court reversed, holding that a parent could only be liable for a subsidiary’s operation of a plant if state law piercing requirements were met, or if the parent and subsidiary operated the plant as a joint venture. The United States appealed.
Rule of Law
Holding and Reasoning (Souter, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 166,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.