Can a landowner raise the third party defense in a claim for wrongful dismissal?

The term "contractual relationship" "includes, but is not limited to, land contracts, deeds or other instruments transferring title or possession." 42 U.S.C. 9601(35)(A). One who opposes assertion of the third party defense must show "something more than a mere contractual relationship." Westwood Pharmaceuticals v. National Fuel Gas Distribution Corp., 964 F.2d 85, 89 (2nd Cir.1992). Thus, "a landowner is precluded from raising the third-party defense only if the contract between the landowner and the third party somehow is connected with the handling of hazardous substances." Id. at 89; see also Shapiro v. Alexanderson, 743 F.Supp. 268, 271 (S.D.N.Y.1990).