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Following the United States Supreme Court’s decision in Atlantic Richfield Company v. Christian, commentators warned the decision would allow a new category of state law actions challenging EPA-approved clean-ups. One year later, Christian does not seem to have opened the flood gates to new litigation, but it may serve to narrow federal jurisdiction over environmental clean-ups.    In Christian, 98 Montana landowners, who were within the boundaries of a Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) Superfund site, brought suit in state court asserting various state law claims related to pollution damage to their property. Part of the damages sought were “restoration” damages, which were meant to restore the landowners’ property to its pre-contaminated condition. Under Montana law, a landowner may seek not only tort damages for diminution in property value, but also restoration damages, even if such efforts are greater than those

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