Alloy Briquetting Corp. v. Niagara Vest, Inc.
Plaintiff sued defendants Niagara Vest and Union Carbide under various federal and state law theories, including CERCLA, to recover costs related to the cleanup of chemical contamination at a property in Niagara Falls, New York. The plaintiff sought recovery for response costs, contribution, common law restitution, a declaratory judgment, common law indemnity, and alleged fraud against Niagara Vest. Defendants moved to dismiss claims related to attorney fees, the entire contribution claim, the declaratory relief claim, and to strike references to future response costs. The court granted the dismissal of claims seeking attorney fees for private parties under both CERCLA and New York State law. Motions regarding declaratory judgment and contribution claims were partially granted and partially denied, differentiating between past and future response costs, with claims for future costs largely dismissed due to the plaintiff's lack of standing after eviction from the site.