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

Facts

American Cyanamid Co. (D) loaded 20,000 gallons of liquid acrylonitrile, a toxic substance, into a leased railroad car in order to ship it to a processing plant in New Jersey. The car arrived in the Blue Island yard, and several hours after it arrived, employees of the switching line noticed fluid gushing from the bottom outlet of the car. The lid on the outlet was broken. The leak was stopped after two hours by closing a shut-off valve controlled from the top of the car. It was feared that all 20,000 gallons had leaked. Acrylonitrile is flammable at a temperature at or above 30 degrees Fahrenheit. It is highly toxic and possibly carcinogenic. Homes near the yard were evacuated. The evacuation lasted a few hours. The car was moved to a remote part of the yard, and it was discovered that only about a quarter of the acrylonitrile had leaked. The Illinois Department of Environmental Protection ordered the switching line to take decontamination measures that cost the line $981,022.75. P sued D to recover the cost of cleanup. P claimed negligence and that the transportation of toxic chemicals was an ultrahazardous activity and D should be strictly liable. P moved for summary judgment on the strict liability count and won. The judge directed the entry of judgment for $981,022.75 under Fed. R. Civ. P. 54(b) to permit Cyanamid to take an immediate appeal even though the negligence count remained pending. D appealed, and the appeals court remanded on the ground that the negligence and strict liability counts were not separate claims but merely separate theories involving the same facts, making Rule 54(b) inapplicable. The district judge, over the switching line's objection, dismissed the negligence claim with prejudice. D then appealed and P cross-appealed, challenging the dismissal of the negligence count.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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