Last year, the U.S. Court of Appeals for the Sixth Circuit decided the case of Hobart Corporation, et al., v. Waste Management of Ohio, Inc., et al., 758 F. 3d 757 (2014), holding that the statute of limitation applicable for the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) cost reimbursement actions is 3 years from the effective date of an administrative settlement with EPA. Yesterday, the Supreme Court denied Hobart's petition for certiorari.