On December 10, 2015, the U.S. Court of Appeals for the 8th Circuit reversed a district court decision that had found, on a motion for summary judgment, that an Iowa company “arranged” for disposal of PCBs under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) when it sold buildings to another party. U.S. v. Dico, Inc., — F.3d —- (2015). The case involved Dico’s sale of buildings in Des Moines, IA, that contained PCBs. Pursuant to an EPA order, Dico had cleaned up the buildings but they still contained PCBs encapsulated in insulation materials. Without notifying EPA, Dico sold the buildings to Southern Iowa Mechanical (SIM). SIM dismantled the buildings and disposed of all materials—including the PCB-containing insulation—except for the buildings’ steel beams,…