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

Brief Fact Summary.

Indiana Harbor Belt Railroad Co. (Plaintiff) sued American Cyanamid Co. (Defendant) for the cost of decontaminating its railroad switching line when Defendant’s dangerous chemical, acrylonitrile, leaked.

Synopsis of Rule of Law.

A strict liability standard is not applicable to cases where the relevant activity is not abnormally dangerous, even if the underlying substance is.

Facts.

American Cyanamid Co. (Defendant) manufactures chemicals including acrylonitrile. Defendant loaded 20,000 gallons of acrylonitrile onto a leased railroad tank car. The car was brought by train to a railroad yard where Indiana Harbor Belt Railroad (Plaintiff) owned a switching line to move cars from one railroad track to another. Plaintiff’s employees noticed that the tank car was leaking acrylonitrile and eventually were able to stop the leak. The Illinois Department of Environmental Protection ordered Plaintiff to decontaminate the site because acrylonitrile is extremely flammable, toxic, and possibly carcinogenic. The decontamination measures cost Plaintiff $981,022.75. Plaintiff sued Defendant for negligence and strict liability to recover this cost.

Issue.

Is transportation of bulk chemicals an abnormally dangerous activity for which the shipper is responsible under the theory of strict liability?

Held.

No, the Court held that a theory of strict liability is not appropriate in this case. The Court reversed and remanded.

Discussion.

The Court believed that negligence is a sufficient standard to hold shippers of dangerous chemicals like acrylonitrile responsible. The leak in this case was not caused because acrylonitrile’s properties make it abnormally dangerous to ship, where it could eat through a tank. The accident here was caused by carelessness.

Instituting a strict liability standard could incentivize shippers to find alternate routes that do not go through metropolitan areas, but the Court believed this would be extremely costly as railroad hubs tend to be in these areas.

The standard of strict liability for abnormally dangerous activities is that the activity be dangerous, not the substance. The Court said while acrylonitrile may have dangerous qualities, transporting it even in bulk through metropolitan areas is not abnormally dangerous.