Western Maryland Railway Co. v. Harbor Insurance Co.

910 F.2d 960 (1990)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

Western Maryland Railway Co. v. Harbor Insurance Co.

United States Court of Appeals for the District of Columbia Circuit
910 F.2d 960 (1990)

  • Written by Heather Whittemore, JD

Facts

A torrent of lawsuits were filed against railroads by employees who developed asbestosis, a lung condition caused by exposure to asbestos fibers. The railroads had indemnity and liability-insurance policies through several insurance companies. In Chesapeake & Ohio Railway v. Certain Underwriters at Lloyd’s, London, three railroads (collectively, the Chesapeake railroads) (plaintiffs) sued 40 insurance companies (defendants) in federal district court based on diversity jurisdiction. In Western Maryland Railway Co. v. Harbor Insurance Co., one railroad (the Western Maryland railroad) (plaintiff) sued nine insurance companies (defendants) in federal district court based on diversity jurisdiction. The Western Maryland railroad was a subsidiary of a Chesapeake railroad, and all nine insurance companies in Western Maryland were defendants in Chesapeake. Both lawsuits revolved around the question of whether the railroad employees’ asbestosis claims were included among the occupational diseases covered by the railroads’ insurance policies. Western Maryland and Chesapeake were in front of the same federal district court judge. All the insurance companies moved to dismiss the cases. The insurance companies argued that the Western Maryland railroad was a necessary party to adjudicate Chesapeake under Federal Rule of Civil Procedure (FRCP) 19(a)(2)(ii) because the separate lawsuits created a risk that the insurance companies would be liable for multiple recoveries. However, because adding the Western Maryland railroad to Chesapeake would destroy diversity, the insurance companies argued that Chesapeake should be dismissed under FRCP 19. The insurance companies also argued that Western Maryland was initiated to create diversity of citizenship, and as a result, that case should also be dismissed for lack of proper jurisdiction. The district court granted both motions and dismissed both cases. The Western Maryland and Chesapeake railroads appealed.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership