CTS Corp. v. Waldburger
134 S. Ct. 2175
| SCOTUS | 2014Background
- CTS Corporation operated an electronics plant in Asheville, NC, stored hazardous solvents (TCE, DCE), and sold the property in 1987.
- Adjacent landowners and later owners sued CTS in 2011 alleging property contamination; plaintiffs say they discovered contamination in 2009.
- North Carolina law contains both a discovery-based statute of limitations and a separate 10-year statute of repose that bars any suit more than 10 years after the defendant’s last culpable act.
- CERCLA §9658 (added 1986) prescribes a federal "federally required commencement date" (discovery rule) for certain state-law personal-injury/property-damage actions from hazardous-substance exposure and purports to displace an earlier state commencement date.
- District Court dismissed under North Carolina’s repose period; the Fourth Circuit reversed, holding §9658 preempts statutes of repose; the Supreme Court granted certiorari.
- The Supreme Court reversed the Fourth Circuit, holding §9658 does not pre-empt state statutes of repose.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §9658 pre-empts state statutes of repose | §9658 implements a discovery rule and should displace any earlier state commencement date (including repose) so long-latency injuries are not time-barred | §9658 speaks only to "statutes of limitations" and does not reach statutes of repose; Congress omitted "repose" and defined terms accordingly | §9658 does not pre-empt statutes of repose; Congress limited pre-emption to statutes of limitations |
| Whether the statutory text/definitions of §9658 include statutes of repose | The statute’s remedial purpose and history (Study Group Report) support reading §9658 to cover repose | The text repeatedly says "statute of limitations" and defines "applicable limitations period" and "commencement date" in ways that presuppose an accrued cause of action — consistent with limitations, not repose | Text and structure point to limitations only; definition of "applicable limitations period" and singular phrasing support exclusion of repose |
| Whether tolling language and equitable tolling implications require pre-emption of repose | Plaintiffs argue equitable considerations support broad pre-emption to effectuate CERCLA’s discovery rule | Tolling provisions in §9658 (special rules for minors/incompetents) and the traditional inapplicability of tolling to repose suggest Congress targeted limitations, not repose | Inclusion of tolling-related provisions implies Congress intended to reach statutes amenable to tolling (limitations), not fixed repose periods |
| Role of presumption against pre-emption and remedial purpose | §9658’s remedial aim (protect long-latency plaintiffs) justifies resolving ambiguity in favor of pre-emption | When text is susceptible to more than one reading, courts should avoid displacing state police powers; pre-emption should not be inferred absent clear congressional intent | Presumption against pre-emption and federalism concerns support a narrow reading; respondents failed to show statutes of repose present an unacceptable obstacle to CERCLA’s purposes |
Key Cases Cited
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (syllabus vs. opinion distinction)
- Burlington N. & S. F. R. Co. v. United States, 556 U.S. 599 (describing CERCLA’s purpose to ensure timely cleanup and allocate costs)
- Bay Area Laundry & Dry Cleaning Pension Trust Fund v. Ferbar Corp. of Cal., 522 U.S. 192 (statute of limitations accrual principles)
- Lampf, Pleva, Lipkind, Prupis & Petigrow v. Gilbertson, 501 U.S. 350 (repose incompatible with tolling)
- Lozano v. Montoya Alvarez, 572 U.S. 1 (equitable tolling doctrine)
- Medtronic, Inc. v. Lohr, 518 U.S. 470 (presumptions about pre-emption and federalism)
- Altria Group, Inc. v. Good, 555 U.S. 70 (favoring reading that disfavors pre-emption when ambiguous)
- Wyeth v. Levine, 555 U.S. 555 (implied pre-emption/obstacle analysis)
- Rice v. Santa Fe Elevator Corp., 331 U.S. 218 (presumption against pre-emption of state police powers)
- Silkwood v. Kerr-McGee Corp., 464 U.S. 238 (states’ traditional role in providing tort remedies)