New Jersey Dept. Environmental v. American Thermoplastics Corp, 974 F.3d 486

The Combe Fill South Landfill Superfund Site in New Jersey was remediated under a USEPA–NJDEP cooperative agreement; USEPA incurred over $104 million and NJDEP about $24 million in response costs.
Carter Day (operator/owner successor) settled with NJDEP in 1991 in bankruptcy, obtaining a court-approved release discharging "all liabilities to NJDEP" for the Site (the NJDEP Settlement); the USEPA was not a party.
In 1998 the United States sued multiple PRPs; a 2009 global Consent Decree (not including Carter Day) allocated most recovery to USEPA; Compaction paid roughly $11 million (split between USEPA and NJDEP) and agreed to a $26 million contingent Consent Judgment.
Compaction sued Carter Day for contribution under CERCLA §113(f) to recoup federal cleanup-related payments; the District Court granted Carter Day summary judgment, holding the NJDEP Settlement barred contribution suits covering the same "matters."
Compaction and the United States appealed; the Third Circuit considered (1) whether the United States had Article III standing to appeal and (2) whether a state settlement (with NJDEP) bars contribution claims for federal response costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a PRP’s settlement with a State (NJDEP) bars contribution claims by other PRPs for federal response costs under CERCLA §113(f)(2)	Compaction/US: NJDEP Settlement only resolved Carter Day’s liability to NJDEP and therefore does not bar contribution claims for USEPA-incurred costs	Carter Day: §113(f)(2) contribution protection covers "matters addressed" by the settlement, which broadly referenced the Site and thus precludes contribution claims as to both State and Federal matters	The Third Circuit reversed: limit "matters addressed" to the sovereign party to the settlement; NJDEP Settlement does not bar contribution claims for federal liability incurred by USEPA
Whether the United States has Article III standing to appeal the District Court’s grant of summary judgment for Carter Day	US: it has a concrete financial stake because the Consent Judgment ties the Government’s recovery to Compaction’s contribution recoveries (and the ruling impedes US recovery)	Carter Day: US’s interest is contingent and speculative; government did not intervene in Carter Day bankruptcy or the NJDEP settlement	The Third Circuit held the US has standing: its financial interest is concrete, traceable, and redressable (the District Court’s ruling impedes the Government’s ability to recover under the Consent Judgment)

CTS Corp. v. Waldburger, 573 U.S. 1 (2014) (stating CERCLA’s purpose to promote timely cleanups and allocate costs to responsible parties)
United States v. Atlantic Research Corp., 551 U.S. 128 (2007) (discussing PRP contribution remedies under CERCLA amendments)
In re Combustion Equip. Assocs., 838 F.2d 35 (2d Cir. 1988) (explaining CERCLA ripeness concerns and deferring liability disputes until remedial plans are set)
Trinity Industries, Inc. v. Chicago Bridge & Iron Co., 735 F.3d 131 (3d Cir. 2013) (interpreting CERCLA settlement-language regarding who has "resolved" liability)
Akzo Coatings, Inc. v. Aigner Corp., 30 F.3d 761 (7th Cir. 1994) (advising narrow interpretation of "matters addressed" when different sovereigns are involved)
United States v. Charter Int’l Oil Co., 83 F.3d 510 (1st Cir. 1996) (on contribution protection and incentivizing settlements)
United States v. Se. Pa. Transp. Auth., 235 F.3d 817 (3d Cir. 2000) (presuming settlements protect settlors from contribution for an entire site absent explicit language)
Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (setting the Article III injury-in-fact standard)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing principles concerning concreteness and imminence)