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Yukon Equipment, Inc. v. Fireman's Fund Insurance Co.

585 P.2d 1206 (1978)

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Yukon Equipment, Inc. v. Fireman’s Fund Insurance Co.

Alaska Supreme Court

585 P.2d 1206 (1978)

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Facts

Yukon Equipment, Inc. (Yukon) (defendant) owned an explosives storage magazine located on federal property near Anchorage, Alaska. At the time that the government had chosen the property for Yukon’s magazine, Anchorage was less populated. Now, however, the area surrounding the magazine was suburban. Vandals broke into the facility several times to steal explosives. Finally, thieves broke into the magazine and ignited 80,000 pounds of explosives, creating an explosion that damaged homes up to two miles away from the site. The Fireman’s Fund Insurance Company (Fireman’s Fund) (plaintiff) sued Yukon, arguing that Yukon was strictly liable for damages caused by the explosion. Fireman’s Fund moved for summary judgment. The trial court granted partial judgment on the issue of liability. Yukon appealed, arguing that strict liability did not apply to Yukon’s storage of explosives. Specifically, Yukon argued that whether storing explosives was an abnormally dangerous activity meriting strict liability must be determined by applying the test outlined by § 520 of the Restatement (Second) of Torts. Additionally, Yukon argued that the thieves’ intentional detonation of the explosives served as an intervening cause that removed Yukon’s liability.

Rule of Law

Issue

Holding and Reasoning (Matthews, J.)

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