Law360, New York ( June 24, 2015, 6:23 PM EDT) -- In the Winter 2015 issue of the American Bar Association's Natural Resources & Environment magazine, John Barkett retraced the U.S. Supreme Court's treatment of the Comprehensive Environmental Response, Compensation, and Liability Act from Key Tronic Corp. v. U.S. to CTS Corp. v. Waldburger and, looking back over that history, he makes the unassailable observation that the Supreme Court's decisions have been, and will continue to be, guided by the plain meaning of CERCLA's text. See e.g., Burlington Northern & Santa Fe Railway v. U.S., 556 U.S. 599 (2009) ("Liability may not extend beyond the limits of the statute itself"); Cooper Industries Inc. v. Aviall Services Inc., 543 U.S. 157 (2004) ("Given the clear meaning of the text, there is no need ... to consult the purpose of CERCLA at all."). While Superfund lawyers and the justices themselves may argue over the plain meaning of a given statutory term or phrase, a majority of the Supreme Court has not deviated from this textual approach to CERCLA disputes....