Editors' Summary: In an early decision on private-party recovery of attorney fees under CERCLA, T&E Industries v. Safety Light Corp., the court refused to create a right to recovery of attorney fees because Congress had not expressly provided that such a right exists. A distinction then evolved in the case law between enforcement-related and response-related attorney fees, and ultimately the Eighth Circuit held in General Electric Co. v. Litton Industrial Automation Systems that attorney fees are recoverable by private parties because the definition of "response" in CERCLA §101(25) includes related enforcement activities. This recent federal appellate court ruling on the recovery of private-party attorney fees under CERCLA follows more than two years of numerous conflicting district court decisions. In light of the decision's potential repercussions on the goal of cleaning up hazardous waste sites, this Article describes the development and present status of the law on private-party recovery of attorney fees under CERCLA and offers suggestions to increase the likelihood of recouping these transaction costs.