In the 1959 Oregon decision of Martin v. Reynolds Metals Co., the supreme court of that state re-investigated the fields of trespass and nuisance and incorporated into the former modern understanding which had previously been excluded from the aged legal concept.
Timothy R. Clifford,
Trespass—Unseen Particles Constituting Invasion—Distinguished from Nuisance,
35 Wash. L. Rev. & St. B.J.
Available at: https://digitalcommons.law.uw.edu/wlr/vol35/iss3/8