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

United States Court of Appeals for the Seventh Circuit
916 F.2d 1174 (7th Cir. 1990)


American Cyanamid Co. (Cyanamid) (defendant) leased a railroad car to ship 20,000 gallons of acrylonitrile, a highly toxic and flammable chemical. The car was handled by Missouri Pacific Railroad (the Railroad) and directed to a yard outside Chicago owned by Indiana Harbor Belt R.R. (Indiana) (plaintiff). When the car arrived, Indiana’s employees noticed it was leaking. Approximately one quarter of the chemical had leaked out. The Illinois Department of Environmental Protection ordered decontamination measures that cost Indiana nearly $1 million. Indiana sued Cyanamid to recover the costs, arguing that Cyanamid had negligently maintained the shipping car and was strictly liable because shipping acrylonitrile through Chicago was an abnormally dangerous activity. The district court granted summary judgment for Cyanamid on the basis of strict liability, and Indiana appealed.

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