August 2011
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Equipment Manufacturer Not Liable As CERCLA Arranger
A recent Ninth Circuit decision refused to hold a manufacturer of a dry cleaning machine liable as an arranger under CERCLA. In Team Enterprises LLC v. Western Investment Real Estate Trust (9th Cir. 2011), plaintiff argued that the requisite “intent to dispose” element necessary to trigger CERCLA arranger liability could be inferred from the fact… Continue reading