United States v. Olin Corporation

CourtCourt of Appeals for the Eleventh Circuit
DecidedMarch 25, 1997
Docket96-6645
StatusPublished

This text of United States v. Olin Corporation (United States v. Olin Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Olin Corporation, (11th Cir. 1997).

Opinion

United States Court of Appeals,

Eleventh Circuit.

No. 96-6645.

USA, acting at request of the Administrator of the United States Environmental Protection Agency (EPA), Plaintiff-Appellant,

v.

OLIN CORPORATION, Defendant-Appellee.

March 25, 1997.

Appeal from the United States District Court for the Southern District of Alabama. (No. 95-0526-BH-S), William Brevard Hand, District Judge.

Before ANDERSON, Circuit Judge, KRAVITCH and HENDERSON, Senior Circuit Judges.

KRAVITCH, Senior Circuit Judge:

Congress passed the Comprehensive Environmental Response,

Compensation, and Liability Act ("CERCLA") to counteract the

environmental threats associated with hazardous waste disposal. In

this case, the district court dismissed the government's complaint

brought under CERCLA against Olin Corporation ("Olin"). It ruled

that: (1) the Constitution prohibits enforcement of CERCLA against

a party if the environmental effects of that party's conduct remain

limited to its own property; and (2) CERCLA's cleanup liability

provisions apply prospectively only. The government appeals and we

reverse.

I.

Olin has operated a chemical manufacturing facility in

McIntosh, Alabama since 1951. Until 1982, the plant produced

mercury- and chlorine-based commercial chemicals that contaminated

significant segments of Olin's property. This appeal involves one such portion of the site, called Operable Unit # 1 ("OU-1").

Groundwater and soil pollution at OU-1 make it unfit for future

residential use. Nevertheless, contamination from OU-1 presently

remains localized to Olin's site because the company regulates

groundwater flow beneath its property.1

II.

The government brought a civil action in the district court,

seeking a cleanup order against Olin and reimbursement for response 2 costs, pursuant to sections 106(a) and 107 of CERCLA. After

negotiations, the parties agreed to a consent decree that called

for Olin to pay all costs associated with remediation of OU-1. The

proposal resolved Olin's liability for contamination at OU-1 caused

by disposal activities before and after CERCLA's effective date of

December 11, 1980, see 42 U.S.C. § 9652(a).

When the parties presented the consent decree to the district

court, it sua sponte ordered them to address the impact of the

Supreme Court's decision in United States v. Lopez, --- U.S. ----,

1 The district court found that contaminants may migrate off-site, if a well in OU-1 should leak. United States v. Olin Corp., 927 F.Supp. 1502, 1506 (S.D.Ala.1996). The government also notes that pollutants from Olin's operations have appeared off-site, albeit within federally-allowed concentration levels. 2 See 42 U.S.C. §§ 9606(a) ("[W]hen the President determines that there may be an imminent and substantial endangerment to the public health or welfare or the environment because of an actual or threatened release of a hazardous substance from a facility, he may require the Attorney General of the United States to secure such relief as may be necessary to abate such a danger or threat and the district court ... shall have jurisdiction to grant such relief as the public interest and the equities of the case may require."); 9607(a)(1)(A), (2)(A) (providing that current and former disposal facility owners and operators are liable for "all costs of removal or remedial action incurred by the United States Government ... not inconsistent with the national contingency plan"). 115 S.Ct. 1624, 131 L.Ed.2d 626 (1995) (invalidating Gun-Free

School Zones Act under the Commerce Clause), on the legality of

their proposal. Olin complied with that order by answering the

original complaint. It asserted that the Lopez Court's

construction of the Commerce Clause precluded constitutional

application of CERCLA in this case. In addition, Olin contended

that CERCLA was not intended to impose liability for conduct

predating the statute's enactment. The district court agreed with

Olin on both counts, denied the motion to enter the consent decree

and dismissed the government's complaint.

III.

We review de novo the constitutional challenge to CERCLA and

the purely legal question of whether the statute's cleanup

liability provisions apply retroactively. See generally Heuer v.

United States Secretary of State, 20 F.3d 424, 426 (11th Cir.),

cert. denied, --- U.S. ----, 115 S.Ct. 573, 130 L.Ed.2d 490 (1994).

A.

The district court found that the enforcement of CERCLA

against Olin violated the Commerce Clause as interpreted by the

Supreme Court in Lopez. The Lopez Court held that the Commerce

Clause empowers Congress to regulate: (1) channels of interstate

commerce; (2) instrumentalities of and persons or things in

interstate commerce; and (3) intrastate activities that

substantially affect interstate commerce. See Lopez, --- U.S. at

---- - ----, 115 S.Ct. at 1629-30. This case, like Lopez, concerns

the third category.

Lopez did not alter the constitutional standard for federal statutes regulating intrastate activities. See id. at ---- - ----,

115 S.Ct. at 1628-30 (documenting consistency of Court's Commerce

Clause jurisprudence since 1942); 1637 (Kennedy, J., concurring)

("Stare decisis operates with great force in counseling us not to

call in question the essential principles now in place respecting

the congressional power to regulate transactions of a commercial

nature."). Simply stated, "the proper test requires an analysis of

whether the regulated activity "substantially affects' interstate

commerce." Id. at ----, 115 S.Ct. at 1630. Congress can maintain

the constitutionality of its statutes under this standard by

including in each a "jurisdictional element which would ensure,

through case-by-case inquiry, that the [regulated activity] in

question affects interstate commerce." Id. at ----, 115 S.Ct. at

1631.3 In addition, Congress, or a committee thereof, can make

legislative findings indicating that a statute regulates activities

with a substantial effect on interstate commerce. See id. If

Congress does so, a court may not override these findings unless

they lack a rational basis. See Cheffer v. Reno, 55 F.3d 1517,

1520-21 (11th Cir.1995) (upholding Freedom of Access to Clinic

Entrances Act because legislative findings were "plausible and

provided rational basis for concluding that the Access Act

regulates activity which "substantially affects' interstate

commerce").

3 This court, for instance, upheld the constitutionality of the federal statute criminalizing firearm possession by felons, 18 U.S.C. § 922(g), because it requires the government to show, in each case, that the defendant's weapon either traveled in or affected commerce. See United States v. McAllister, 77 F.3d 387 (11th Cir.), cert. denied, --- U.S. ----, 117 S.Ct.

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