Seventh Circuit Draws a Line on Awards of Injunctive Relief Under RCRA

While RCRA’s citizen suit provision broadly authorizes injunctive relief where contamination poses an “imminent and substantial endangerment,” the Seventh Circuit’s decision in LAJIM, LLC v. General Electric Co. confirms that such relief is not automatic. Even where liability is established, courts retain discretion to deny an injunction if existing state enforcement actions and consent orders are already addressing the alleged harm. The decision also reinforces that RCRA provides only equitable relief—not damages—and clarifies that, under Illinois law, the continued migration of historical contamination does not constitute a “continuing tort” sufficient to avoid statutes of limitation.