By Toni Finger (September 11, 2017, 11:52 AM EDT) -- Section 113 of the Comprehensive Environmental Response, Compensation, and Liability Act, (CERCLA) allows parties that have cleaned up hazardous waste pursuant to a settlement agreement with the government to seek contribution from any other potentially responsible party (PRP) that is not a party to the agreement. Specifically, §113(f)(3)(B), provides a right of contribution for "[a] person who has resolved its liability to the United States or a state for some or all of a response action or for some or all of the costs of such action in an administrative or judicially approved settlement." Many courts have grappled with interpreting this statutory provision while assessing whether a party is entitled to a contribution claim....