United States v. Monsanto Co.
United States Court of Appeals for the Fourth Circuit
858 F.3d 160 (1988)
Oscar Seidenberg and Harvey Hutchinson (defendants) leased a tract of land (the property) to the Columbia Organic Chemical Company (COCC) (defendant). COCC’s principals incorporated South Carolina Recycling and Disposal Inc. (SCRDI) (defendant) for the purpose of assuming COCC’s waste-handling business. SCRDI contracted with waste producers for the transport, recycling, and storing of hazardous waste. SCRDI haphazardly stored the waste on the property. The waste was kept in rusted drums, without regard to the chemical compatibility of the various waste products. As a result, in 1977, a toxic cloud formed when chemicals leaking from rusted drums reacted with rainwater, resulting in the hospitalization of 12 firemen. In 1979, an explosion and fire resulted when chemicals stored in glass jars leaked onto drums containing incompatible substances. The site manager for SCRDI could not identify the chemicals that caused the explosion, which made the fire difficult to extinguish. The United States (plaintiff) filed suit under § 107(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) against SCRDI, COCC, Seidenberg and Hutchinson. Additionally, the United States sued Allied Corporation, Monsanto Company, and EM Industries, Inc. (defendants), who had generated the waste. The United States argued the defendants were jointly and severally liable for the response costs of the toxic cloud, explosion, and fire under CERCLA. The defendants argued their conduct did not cause the damage, and they could not be liable under CERCLA. Alternatively, the defendants argued CERCLA’s liability scheme was retroactive and thus unconstitutional. The district court held that all defendants were strictly, and jointly and severally, liable under CERCLA. The district court further held CERCLA was prospective, directed at post-enactment consequences of past acts, and not retroactive. Alternatively, the district held that CERCLA, even if retroactive, was rationally related to a valid legislative purpose and therefore constitutional. Seidenberg, Hutchinson, Allied, Monsanto, and EM Industries appealed.
Rule of Law
Holding and Reasoning (Sprouse, 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 724,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead 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.Learn about our approachRead more about Quimbee
Here's why 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,600 briefs, keyed to 983 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.