Steeltech, Ltd. v. United States Environmental Protection Agency

OPINION

MOORE, Circuit Judge.

Plaintiff-Appellant Steeltech, Ltd., appeals the district court’s affirmance of the civil penalty imposed by an EPA administrative law judge (“ALJ”) under the Emergency Planning and Community Right-to-Know Act (“EPCRA”), 42 U.S.C. §§ 11001-11050, for Steeltech’s failure to file timely reports regarding its processing of toxic chemicals. Steeltech has not contested its liability under EPCRA, a strict liability statute; instead, Steeltech contends that the civil penalty assessed by the EPA is excessive because the agency failed to give due consideration to the…