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

Yukon Equipment, Inc. (defendant) stored explosives in a magazine on federal land near Anchorage. The area had been sparsely populated when the site was chosen, but by the time of the incident it had grown into a suburb. Vandals broke into the facility several times to steal explosives, and thieves eventually broke in and detonated 80,000 pounds of explosives, damaging homes up to two miles away. Fireman's Fund Insurance Co. (plaintiff) sued Yukon on a strict-liability theory and moved for summary judgment on liability, which the trial court granted in part. Yukon appealed, arguing storing explosives was not abnormally dangerous under Restatement (Second) of Torts section 520, and that the thieves' intentional detonation was a superseding cause cutting off its liability.

Whether a defendant engaged in an abnormally dangerous activity is liable when an unforeseeable intervening cause injures a plaintiff in the same way the defendant's activity had always threatened to do.