November 19, 2020. U.S. District Judge Mark A. Goldsmith cited Professor Steve Gold’s 2009 article, “Dis-Jointed? Several Approaches to Divisibility After Burlington Northern” in a decision that rejected a Superfund site owner’s attempt to avoid liability for cleanup of the site. “Legal scholars have likewise noted the anomalies that would arise” if the site owner’s argument were accepted. Gould Electronics, Inc. v. Livingston County Road Commission, 2020 WL 6793335 at *41 n.30 (E.D. Mich. Nov. 19, 2020).