Rice v. Marathon Petroleum Corporation

In a case arising out injuries the plaintiff sustained from an explosion caused by an underground storage tank that leaked gasoline, the Illinois Supreme Court considered whether various Illinois environmental statutes and regulations governing underground storage tanks created a private right of action. The circuit court dismissed the plaintiff’s statutory claims for failure to state a valid cause of action and the appellate court affirmed. The supreme court also affirmed, agreeing with the lower courts that the applicable statutes did not create either an express or implied private statutory rights of action. (THEIS, NEVILLE, OVERSTREET, HOLDER WHITE, and CUNNINGHAM, concurring. ROCHFORD took no part in the decision.)