A district court held that the United States is an arranger and operator under CERCLA with regard to the waste disposal sites at four phosphate mines in the Caribou-Targhee National Forest.

The Fifth Circuit held that the Superfund Recycling Equity Act (SREA)—an amendment to CERCLA that exempts certain recyclers from liability for cleanup costs under CERCLA and awards costs and fees to any recyclers improperly sued for contribution under CERCLA—does not apply to state-law actions.