Utah Supreme Court

When does a cause of action accrue under Utah's Underground Storage Tank Act? Utah Dept. of Environmental Quality v. Redd Explained

2002 UT 50
Nos. 20010070, 20010105
May 17, 2002
Affirmed

Summary

The Utah Department of Environmental Quality sought to recover cleanup costs for petroleum contamination at a Monticello gas station under the Underground Storage Tank Act. The district court granted partial summary judgment, finding that costs incurred before September 15, 1995, were time-barred but costs incurred after that date were recoverable.

Analysis

In Utah Department of Environmental Quality v. Redd, the Utah Supreme Court addressed a critical question about when statute of limitations periods begin to run in environmental cost recovery actions under Utah’s Underground Storage Tank Act (USTA).

Background and Facts

In 1991, petroleum contamination was discovered at a Monticello gas station during tank removal. The Utah Department of Environmental Quality ordered the property owners, including K. Brent Redd and Woody’s Enterprises, to clean up the released petroleum. When the defendants failed to take corrective action, the state began its own cleanup efforts in early 1995 and continued incurring costs through at least November 1999. The state filed its cost recovery action on September 16, 1998, seeking reimbursement for past and future cleanup expenses.

Key Legal Issues

The central issue was determining when the state’s cause of action accrued under the USTA for purposes of applying the three-year statute of limitations in Utah Code section 78-12-26(4). The defendants argued the entire action accrued when the state first incurred cleanup costs, while the state contended that each cleanup payment created a separate cause of action.

Court’s Analysis and Holding

The Utah Supreme Court established a three-part test for determining when a cause of action accrues under the USTA. The court held that no cause of action exists until: (1) the state orders responsible parties to remedy petroleum contamination, (2) the responsible parties fail to take corrective action, and (3) the state actually incurs cleanup costs. Importantly, the court ruled that each cleanup payment creates a new cause of action with its own three-year limitations period. Applying this framework, the court affirmed the district court’s ruling that costs incurred before September 15, 1995, were time-barred, but costs incurred between September 16, 1995, and September 16, 1998, remained recoverable.

Practice Implications

This decision establishes important precedent for environmental litigation in Utah. Practitioners representing state agencies should carefully document the timing of cleanup orders, defendants’ refusal to act, and actual cost expenditures to maximize recovery potential. Defense counsel should closely scrutinize the timing of each claimed expense to identify potential statute of limitations defenses. The ruling also clarifies that environmental cost recovery actions can involve multiple accrual dates, requiring careful case management to track various limitations periods throughout ongoing cleanup efforts.

Original Opinion

Link to Original Case

Case Details

Case Name

Utah Dept. of Environmental Quality v. Redd

Citation

2002 UT 50

Court

Utah Supreme Court

Case Number

Nos. 20010070, 20010105

Date Decided

May 17, 2002

Outcome

Affirmed

Holding

A cause of action for statutory cost recovery under the Underground Storage Tank Act accrues when the state orders cleanup, the responsible party refuses to act, and the state incurs cleanup costs, with each cleanup payment creating a new cause of action subject to a three-year limitations period.

Standard of Review

Correctness for questions of law and statutory interpretation

Practice Tip

When representing clients in environmental cost recovery actions, carefully document the timing of cleanup orders, refusal to comply, and actual cost incurrence to properly calculate statute of limitations periods for each recoverable expense.

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