In a prior post it was noted that the E.D. Wisconsin Federal District Court had held that a party with a valid contribution claim under CERCLA Section 113 could not validly state a like claim under CERCLA Section 107. In City of Rialto et al v. U.S. Department of Defense et al, 274 Fed. Appx. 515 (9th Cir. 2008), the Ninth Circuit reached a similar conclusion: "The [U.S. Supreme] Court explained that CERCLA 113(f) grants an explicit right to contribution to PRPs and that Section 107(a), by contrast, 'permits recovery of cleanup costs but does not create a right to contribution. . . . Accordingly, the remedies available in Sections 107(a) and 113(f) complement each other by providing causes of action 'to persons in different procedural circumstances.' ... Under Atlantic Research, therefore, a PRP has the right to bring a cost-recovery action under Section 107(a), but may not bring a claim for contribution under § 107."