Indiana Harbor Belt R.R. Co. v. American Cyanamid Co. case brief
Facts: Cyanamid is a manufacturer of chemicals including acrylonitrile, which is a chemical used in large quantities for making acrylic fibers, plastics, dyes, chemicals, etc. The company loaded up a railroad tank with 20k gallons and sent it on its way to Blue Island yard. While there, several employees noticed fluid gushing from bottom of the outlet of the car; the lid on the outlet was broken. After two hours, supervisor of equipment stopped the leak; no one knew how much leaked but they thought it was a lot and were worried that it was flammable because of a low temperature. Plus worries of toxicity and cancer being caused. Yard was evacuated for a few hours and they discovered that only a quarter of the chemical had leaked but still they had concerns. They were ordered to take decontamination measures which it sought to recover from Cyanamid in this suit. It was two counts, one for negligence and one for strict liability because shipping chemical in bulk is an abnormally dangerous activity that they are responsible for. Plaintiff won in trial.
Decision: Reversed and remanded, verdict for defendant.
Reasoning: There are six factors that are used to determine of strict liability should be used in a case, these factors are used to decide whether an activity is abnormally dangerous and if the actor should be strictly liable.
Note: If there is negligence then strict liability is not necessary, you can just use negligence claims for proving your case. Strict liability is used when there is no fault but you still want to hold someone responsible for performing a dangerous activity. Point of strict liability is not to encourage people to be more careful but actually to figure out a better way to do their activities.
Factors are: a. existence of a high degree of risk of harm, b. likelihood that the harm will be great c. inability to eliminate risk by exercise of reasonable care, d. extent to which activity is not of common usage, e. inappropriateness of the activity to place its carried out on and f. extent to which its value to community is outweighed by dangerous attributes
Said that accidents like the one here can be prevented with due care, and a lack of care can be prevented by taking care and when a lack of care is shown, these accidents are adequately deterred by threat of liability for negligence. The court started applying the factors and decided that when you apply them, no reason to impose strict liability. Relevant activity in this case is transportation and it is the transportation company that made mistakes.
Holding: A shipper of dangerous goods does not have a claim against a manufacturer of dangerous goods for strict liability when the factors from the restatement suggest that it was not an abnormally dangerous activity that could be done differently and where negligence was present.