## Facts

- A textile mill site in North Smithfield, Rhode Island, was owned and operated by Stamina Mills, Inc. from 1952 to 1975.
- In 1969, Stamina switched from a soap-scouring system to using trichloroethylene (TCE) in an effort to reduce river pollution.
- Soon after the switch, a tanker driver accidentally released an unknown quantity of TCE onto the ground by improperly attaching a hose coupling to the site’s TCE storage tank.
- In 1979–1980, state agencies investigated and concluded that nearby residential wells were contaminated with TCE originating from the site.
- Hydro-Manufacturing, Inc. later purchased the property, incurred costs related to contamination and its consequences, and sued Kayser-Roth Corporation as corporate successor to Stamina’s parent.

## Issues

1. Whether a subsequent purchaser of contaminated property may maintain Rhode Island common-law claims (including nuisance and negligence) against a predecessor’s corporate successor for pre-existing contamination.
2. Whether liability, contribution, allocation, and cost-recovery disputes arising from historic hazardous-substance releases should be pursued through CERCLA rather than state tort theories.

## Decision

- The Rhode Island Supreme Court affirmed summary judgment for Kayser-Roth.
- The court held that Hydro could not maintain the asserted Rhode Island common-law claims for damages arising from pre-existing contamination.
- The court concluded that disputes over responsibility and reimbursement for removal or remedial actions in this setting are generally actionable under CERCLA’s statutory scheme, not through the state-law causes pleaded.
- Because Hydro’s claims failed as a matter of law, there was no genuine issue of material fact, making summary judgment appropriate.

## Legal Principles

- Summary judgment is proper when there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.
- Under Rhode Island law, a private nuisance claim concerns an unreasonable use of one’s property that materially interferes with a neighbor’s comfort or use of real estate; a later purchaser seeking to recover for conditions on the purchased land does not fit that model.
- In environmental contamination disputes involving response costs, liability, contribution, and allocation are generally addressed through CERCLA’s comprehensive remedial framework rather than by extending Rhode Island common-law tort remedies to subsequent purchasers.

## Conclusion

The court rejected a subsequent purchaser’s attempt to recover cleanup-related damages for historic contamination through Rhode Island nuisance and negligence theories, reasoning that these disputes are generally governed by CERCLA and that the pleaded state-law causes of action did not apply on the facts presented.


Hydro-Manufacturing, Inc. v. Kayser-Roth Corp., 640 A.2d 950 (R.I. 1994)