Industry has won the first round in the ongoing skirmish to determine whether local governments and municipalities are subject to the strict, joint, and several liability scheme of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)¹ for the disposal of household garbage, or municipal solid waste (MSW), at municipal landfill sites across the country. In the first decisions to address the issue, U.S. District Courts in Connecticut and California have ruled that MSW is not automatically exempt from coverage as a "hazardous substance" under §101(14) of CERCLA.²