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Indiana Harbor Belt Railroad Co. v. American Cyanamid Co.

(1990)

United States Court of Appeals for the Seventh Circuit - 916 F.2d 1174

tl;dr:

Plaintiff sued Defendant over spilled chemicals along the railroad; Court holds that a negligence standard, and not strict liability, should be applied.

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ICRAIssue, Conclusion, Rule, Analysis for Indiana Harbor Belt Railroad Co. v. American Cyanamid Co.

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Facts & HoldingIndiana Harbor Belt Railroad Co. v. American Cyanamid Co. case brief facts & holding

Facts:Defendant chemical manufacturer was transporting chemicals via the railroad and...

Holding:The Court of Appeals reversed and remanded.Writing the opinion, Judge...

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Indiana Harbor Belt Railroad Co. v. American Cyanamid Co. | Case Brief DeepDive
Majority opinion, author: POSNER, Circuit Judge.
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American Cyanamid Company leased a railroad tank car filled with liquid acrylonitrile that leaked during transportation, causing the Illinois Department of Environmental Protection to order decontamination measures costing $981,022.75. The switching line won summary judgment on the strict liability count and was awarded the cost of decontamination. The negligence claim was dismissed with prejudice, but Cyanamid filed an appeal, and the switching line cross-appealed. The Supreme Court of Illinois considered the Restatement (Second) of Torts § 520, which outlines six factors to determine whether an activity is abnormally dangerous and the actor is strictly liable. The court rejected the proposal to impose broad liability in this case, as legal precedents have rejected such liability in similar cases. The fact that Cyanamid leased and filled the car was irrelevant, as all that mattered was that Cyanamid introduced the product into the stream of commerce that passed through the Chicago metropolitan area.

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