Editors' Summary: One of the landmark environmental decisions handed down by the Supreme Court in recent years is Tull v. United States, holding that defendants have a right to a jury trial to determine liability for government-sought civil penalties. The decision is based on the Constitution's Seventh Amendment, and so is probably more permanent than an opinion based on statutory interpretation, which the Environmental Protection Agency could seek statutory amendments to effectively reverse. By and large, the government will have to live with the Tull decision, especially since the Supreme Court was unanimous in its core holding. Consequently, the Tull case has wide-ranging implications for the way the Environmental Protection Agency conducts its civil Penalty enforcement, as analyzed in the August 1987 issue of ELR (17 ELR 10304). It also has implications for EPA's Superfund program, which present fundamentally different legal issues. In this Article, the author explores the effects of Tull on the Superfund program, concluding that though jury trials will not be required in government actions to recover response costs or to obtain injunctive relief, jury trials are constitutionally required in actions to impose civil penalties and, probably, to recover for natural resource damages under Superfund.