Pennsylvania v. Union Gas Co.: Difference between revisions
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(Created page with "{{Infobox Case Brief |court=U.S. Supreme Court |citation=491 U.S. 1 (1989) |date=June 15, 1989 |subject=Constitutional Law |appealed_from=U.S. Court of Appeals, 3rd Circuit |c...") |
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|cited=Dellmuth v. Muth* Atascadero State Hospital v. Scanlon | |cited=Dellmuth v. Muth* Atascadero State Hospital v. Scanlon | ||
|followed=Employees v. Missouri Dept. of Public Health and Welfare | |followed=Fitzpatrick v. Bitzer* Employees v. Missouri Dept. of Public Health and Welfare* Parden v. Terminal Railway of Alabama Docks Dept. | ||
|facts=A predecessor to Union Gas Co. operated a coal gasification plant along a creek. The gasification plant produced coal tar as a byproduct. Later, the State struct a deposit of coal tar, which began seeping into the creek. | |facts=A predecessor to Union Gas Co. operated a coal gasification plant along a creek. The gasification plant produced coal tar as a byproduct. Later, the State struct a deposit of coal tar, which began seeping into the creek. | ||
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Revision as of 00:01, September 14, 2020
| Pennsylvania v. Union Gas Co. | |
| Court | U.S. Supreme Court |
|---|---|
| Citation | 491 U.S. 1 (1989) |
| Date decided | June 15, 1989 |
| Appealed from | U.S. Court of Appeals, 3rd Circuit |
| Cited | Dellmuth v. Muth Atascadero State Hospital v. Scanlon |
| Followed | Fitzpatrick v. Bitzer Employees v. Missouri Dept. of Public Health and Welfare Parden v. Terminal Railway of Alabama Docks Dept. |
| Overturned by | |
| Seminole Tribe of Florida v. Florida | |
| Case Opinions | |
| majority | written by William J. Brennan, Jr. |
Facts
A predecessor to Union Gas Co. operated a coal gasification plant along a creek. The gasification plant produced coal tar as a byproduct. Later, the State struct a deposit of coal tar, which began seeping into the creek.
The EPA declared the site a Superfund site. Pennsylvania and the Federal Government jointly remediated the site, and the Federal Government reimbursed the state its costs.Procedural History
The Federal Government sued Union Gas Co. to recoup the cleanup costs under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA).
Union Gas Co. filed a third-party complaint against the State. The District Court dismissed the third-party complaint on the ground that the State's Eleventh Amendment immunity barred the suit.
The Court of Appeals held that the statute rendered States liable for monetary damages, and that Congress had the power to do so under the Commerce Clause.Issues
Did Congress have the power to allow States to be liable under the statute?
Holding
Yes.
Judgment
Affirmed and remanded
Reasons
"Congress has the authority to override States' immunity when legislating pursuant to the Commerce Clause."
"...because the congressional power thus conferred would be incomplete without the authority to render States liable in damages, it must be that, to the extent that the States gave Congress the authority to regulate commerce, they also relinquished their immunity where Congress found it necessary, in exercising this authority, to render them liable"
