Citizens Development Corp., Inc. v. San Diego, County of
ELR Citation: 47 ELR 20051 No(s). 12CV0334 GPC KSC (S.D. Cal. Mar 23, 2017) (Curiel, J.)
A district court held that cow manure can be a hazardous substance under CERCLA. A citizen group sued a dairy farm for its part in contaminating Lake San Marcos. The dairy farm moved for judgment on the pleadings on the grounds that no actionable hazardous release was claimed. The court held that CE...