United States v. Olin Corp. case brief

United States v. Olin Corp. case brief

107 F.3d 1506 (11th Cir. 1997)

CASE SYNOPSIS: Appellant government sought review of the order from the United States District Court for the Southern District of Alabama, which dismissed appellant's complaint brought under the Comprehensive Environmental Response, Compensation, and Liability Act against appellee corporation for pollution located on appellee's property.

FACTS: Appellee corporation operated a chemical manufacturing plant. The plant produced commercial chemicals that contaminated corporate property. Groundwater and soil pollution at the site made it unfit for future residential use. Appellant government brought an action under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) against appellee for pollution on the property. The district court dismissed the action. Appellant sought review. 

DISCUSSION

• The court reversed the district court and remanded the matter. 
• The court found that the district court's U.S. Const. art. 1§ 8, Commerce Clause, analysis conflicted with the proper standard. 
• The court concluded that the statute was valid as applied in this case because it regulated a class of activities that substantially affects interstate commerce. 
• The court held that CERCLA constituted a permissible exercise of Congress's authority under the Commerce Clause. 
• The court noted that CERCLA's purpose, as evinced by the statute's structure and legislative history, also supported the view that Congress intended the statute to impose retroactive liability for environmental cleanup.

CONCLUSION: The court reversed the order of the district court that dismissed the complaint of appellant government brought under the Comprehensive Environmental Response, Compensation, and Liability Act against appellee corporation for cleanup of pollution on appellee's property. The court held that the district court's analysis was incorrect and found clear congressional intent favoring retroactive application of the statute's liability provision.

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