Is a corporate parent entity liable for its subsidiary under CERCLA and the Texas SWDA?

In United States v. Bestfoods, the Supreme Court held that a parent corporation may be charged with derivative CERCLA liability for its subsidiary’s actions when (and only when) the corporate veil may be pierced.  The Court held that a corporate parent is not directly liable under CERCLA unless it actively participated in, and exercised control over, the operations of its subsidiary. 

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