By Andy Thompson, athompson@sgrlaw.com In a March 6, 2012 decision, the U.S. Court of Appeals for the Eleventh Circuit held that parties who enter into a consent decree with the U.S. Environmental Protection Agency (EPA) following an EPA enforcement action and then seek recovery of cleanup costs from other potentially responsible parties (PRPs) are limited to a contribution claim under § 113(f) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and may not simultaneously pursue a cost recovery action under § 107(a) of CERCLA. In the case of Solutia, Inc., et al. v. McWane, Inc., et al., the… Read more