Guam v. United States
View Official PDFSummary
A short, plain-English overview of Guam v. United States.
The Supreme Court addressed a dispute between Guam and the United States regarding liability for environmental hazards at the Ordot Dump. The Court examined whether a settlement of environmental liabilities under other laws could give rise to a CERCLA contribution claim. The Court concluded that a settlement must resolve a CERCLA-specific liability to authorize a contribution action under § 113(f)(3)(B).
Holding
The single most important “bottom line” of what the Court decided in Guam v. United States.
The Court held that a settlement of environmental liabilities must resolve a CERCLA-specific liability to give rise to a contribution action under § 113(f)(3)(B).
Key Quotes
Short excerpts from the syllabus in Guam v. United States that support the summary and concepts above.
A settlement of environmental liabilities must resolve a CERCLA-specific liability to give rise to a contribution action under § 113(f)(3)(B).
The most natural reading of § 113(f)(3)(B) is that a party may seek contribution under CERCLA only after settling a CERCLA-specific liability.
Interpreting § 113(f)(3)(B) to authorize a contribution right for a host of environmental liabilities arising under other laws would stretch the statute beyond Congress' actual language.
