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CTS Corp. v. Waldburger

ELR Citation: 44 ELR 20125
Nos. 13-339, (U.S., 06/09/2014)

The U.S. Supreme Court held that CERCLA §309 does not preempt a state's statute of repose. The case arose after property owners filed suit against a manufacturing company for alleged groundwater contamination stemming from chemicals stored on property the company sold 24 years ago. The company argued that the case should be dismissed because the North Carolina statute of repose bars tort actions brought more than 10 years after the defendant's last culpable act. A district court agreed and granted the company's motion to dismiss, but the U.S. Court of Appeals for the Fourth Circuit reversed, finding that the remedial purposes of CERCLA §309, which preempts statutes of limitations applicable to state law tort actions, favored preemption in this case. The Supreme Court reversed. Statutes of limitations and statutes of repose are both used to limit the temporal extent or duration of tort liability, but their specified time periods are measured differently due to their different purposes and objectives. Statutes of limitations are designed to promote justice by encouraging plaintiffs to pursue claims diligently and begin to run when a claim accrues. Statutes of repose effect a legislative judgment that a defendant should be free from liability after a legislatively determined amount of time and are measured from the date of the defendant's last culpable act or omission. Because a statute of limitations' purpose is not furthered by barring an untimely action brought by a plaintiff who was prevented by extraordinary circumstances from timely filing, equitable tolling operates to pause the running of the statute. The purpose of statutes of repose are unaffected by such circumstances; as such, equitable tolling does not apply. While CERCLA §309 preempts state statute of limitations, it makes no mention of a state statute of repose. The Court therefore held that Congress did not intend to preempt statutes of repose when it enacted §309. Kennedy, J., delivered the opinion of the Court, except as to Part II-D. Sotomayor, and Kagan, JJ., joined that opinion in full, and Roberts, C.J., and Scalia, Thomas, and Alito, JJ., joined as to all but Part II-D. Scalia, J., filed an opinion concurring in part and concurring in the judgment, in which Roberts, C.J., and Thomas and Alito, JJ., joined. Ginsburg, J., filed a dissenting opinion, in which Breyer, J., joined.