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State, Department of Environmental Protection v. Eastman Chemical Co.

Citations: 699 So. 2d 1051; 1997 Fla. App. LEXIS 11224; 1997 WL 614994Docket: No. 96-2969

Court: District Court of Appeal of Florida; October 8, 1997; Florida; State Appellate Court

Narrative Opinion Summary

Summary judgment was granted in favor of Eastman Chemical Company, determining that under Florida’s mini-CERCLA Acts (sections 376.308 and 403.727, Florida Statutes, 1995), a manufacturer is not liable for groundwater contamination resulting from its product being transported by independent contractors. Liability does not arise when the product is delivered to the purchaser, and ownership has transferred according to the sales agreement. The contamination occurred during unloading by the purchaser's employees, which further absolves the manufacturer of responsibility. This decision aligns with precedents set in ES Robbins Corp. v. Eastman Chem. Co. and other relevant cases, and the ruling was affirmed.

Legal Issues Addressed

Consistency with Legal Precedent

Application: The decision aligns with existing legal precedents, confirming the court's interpretation of liability under similar circumstances.

Reasoning: This decision aligns with precedents set in ES Robbins Corp. v. Eastman Chem. Co. and other relevant cases, and the ruling was affirmed.

Manufacturer Liability under Florida's Mini-CERCLA Acts

Application: The court determined that a manufacturer is not liable for groundwater contamination once the product has been delivered and ownership transferred, even if the contamination occurs during unloading by the purchaser's employees.

Reasoning: Summary judgment was granted in favor of Eastman Chemical Company, determining that under Florida’s mini-CERCLA Acts (sections 376.308 and 403.727, Florida Statutes, 1995), a manufacturer is not liable for groundwater contamination resulting from its product being transported by independent contractors.

Responsibility of Purchaser's Employees in Contamination

Application: The court found that the contamination occurring during unloading by the purchaser's employees absolves the manufacturer of responsibility.

Reasoning: The contamination occurred during unloading by the purchaser's employees, which further absolves the manufacturer of responsibility.

Transfer of Ownership and Liability

Application: Liability does not arise for the manufacturer after ownership of the product has been transferred to the purchaser according to the sales agreement.

Reasoning: Liability does not arise when the product is delivered to the purchaser, and ownership has transferred according to the sales agreement.