FEDERALCourt of Appeals for the D.C. Circuit
1994

3m Company v. Carol M. Browner

17 F.3d 1453Court of Appeals for the D.C. Circuit • Decided 1994Enforced
Liquidated DamagesCited 77 times

HOLDING

3M Company challenged EPA penalties for environmental violations, arguing the five-year statute of limitations in federal law didn't apply to EPA administrative proceedings. The court ruled that the five-year deadline does apply, and it starts from the date the violation occurred—not when the EPA discovered it. This matters to subcontractors because it sets a firm deadline for when agencies can pursue penalties for past violations.

KEY FINDINGS

Liquidated Damages

The five-year statute of limitations clock starts when you violate environmental rules, not when the agency finds out about it. Keep detailed records of all compliance activities.

FULL COURT OPINION