United States v. Monstanto Co.
United States Court of Appeals for the Fourth Circuit
858 F.2d 160 (1988)
Seidenberg and Hutchinson were owners of a tract of land that they leased to the Columbia Organic Chemical Company (COCC), a chemical company. COCC stored raw materials and finished products on the land. COCC later began to recycle waste generated by other companies and used the leased land to store and dispose of chemical waste. COCC created South Carolina Recycling and Disposal Inc. (SCRDI) to carry on that business. Federal law defined many of these chemicals as hazardous. Between 1976 and 1980, SCRDI haphazardly stored 7,000 55-gallon drums of waste wherever there was space and without additional protective measures. Many of these drums decayed and leaked their contents into the ground. The various chemicals leaked and interacted with each other, resulting in dangerous fumes, fires, and explosions on multiple occasions. A government investigation found that the facility was filled beyond capacity and that many of the drums were unlabeled or had labels that were unreadable. The United States and the State of South Carolina (plaintiffs) sued COCC, SCRDI, Seidenberg, Hutchinson, and several off-site chemical producers whose waste was found at the site, claiming violation of Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). Several defendants settled, but the landowners and three others did not. The district court held all the non-settling defendants jointly and severally liable for the cost of cleaning up the site. Defendants appealed.
Rule of Law
Holding and Reasoning (Sprouse, J.)
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