Philip Carey Co. owned a tract of land in Plymouth Township, Pennsylvania, on which it deposited a large pile of manufacturing waste containing asbestos.

Carey sold the land to Celotex, and Celotex sold the land to Smith Land &

Improvement Corp. The EPA notified Smith that unless it took steps to eliminate the asbestos hazard, the EPA would do the work and pursue reimbursement. Smith cleaned up the land to the EPA’s satisfaction at a cost of

$218,945.44. Smith asked Celotex and Carey for reimbursement. Which firms 1208 Part 8 Real Property and Estates have liability for the cleanup costs? [Smith Land & Improvement Corp. v Celotex, 851 F2d 86 (3d Cir)]

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