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

American Cyanamid (defendant) leased a railroad car to ship 20,000 gallons of acrylonitrile, a toxic, flammable chemical, and the car was routed through a rail yard near Chicago owned by Indiana Harbor Belt (plaintiff), where employees discovered it leaking, having already lost roughly a quarter of its contents; Illinois environmental regulators ordered nearly $1 million in decontamination measures, which Indiana Harbor Belt sought to recover from Cyanamid, arguing both negligent maintenance of the car and strict liability for engaging in an abnormally dangerous activity. The district court granted Indiana summary judgment on strict liability and dismissed the negligence claim, and both sides appealed.