Supreme Court of the United States
Meghrig v. Kfc Western, Inc.
March 19, 1996516 U.S. 479
Summary
Justice O’Connor delivered the unanimous opinion holding that RCRA’s citizen-suit provision does not authorize recovery of costs incurred in a past cleanup and requires an allegation that the contamination presents an imminent and substantial endangerment when suit is filed. The statutory remedies authorize prospective injunctive relief, not compensation for completed cleanup efforts, and courts cannot imply additional remedies inconsistent with Congress’s enforcement scheme. The Court reversed the Ninth Circuit and expressly left open whether relief could cover cleanup costs incurred after a citizen suit is properly commenced. There were no separate opinions.
Holding
- Recovery of past cleanup costs under RCRA’s citizen-suit provision.. A private party cannot recover the cost of a past cleanup effort under § 6972(a), whether characterized as damages or equitable restitution.
- Timing of the imminent-and-substantial-endangerment requirement.. Section 6972(a)(1)(B) requires an allegation that the contaminated site presently poses an imminent and substantial endangerment when suit is filed; an endangerment existing only before cleanup is insufficient.
Docket 95-83
Cited authorities
- 42 U.S.C. § 6972
- 90 Stat. 2825
- 482 U.S.C. § 6972
- 42 U.S.C. § 6903
- 94 Stat. 2767
- 42 U.S.C. § 9601
- 42 U.S.C. § 6902
- 42 U.S.C. § 6903
Cited by
- Maka Hospice, Inc. v. Alex M. Azar, II
- City of West Sacramento v. R & L Business Management
- City of West Sacramento v. R & L Business Management
- City of West Sacramento v. R & L Business Management
- P.p. v. Compton Unified School District
- María G. Abreu v. the United States, Donald H. Rumsfeld
- Toxics Action Center, Inc. v. Casella Waste Systems, Inc.
- State of Texas v. United States of America