1990), is a decision of the United States Court of Appeals for the Seventh Circuit authored by Judge Richard Posner.

[3] However, several hours after the car arrived at the Blue Island Rail Yard in Riverdale, Illinois (on Riverdale's border with Blue Island, Illinois), Indiana Harbor Belt Railroad employees noticed that acrylonitrile was gushing out of the car because the lid on the outlet was broken.

[3] Concerned because acrylonitrile is flammable, highly toxic, and possibly a carcinogen, local officials ordered an evacuation until the leak could be stopped and the car moved to a remote part of the rail yard.

[3] American Cyanamid moved to dismiss Indiana Harbor Belt Railroad's strict liability claim against it, but the district judge denied this motion.

[3] The district judge then dismissed Indiana Harbor Belt Railroad's negligence claim so that American Cyanamid could appeal the strict liability decision to the Seventh Circuit.

The court rejected a number of arguments made by Indiana Harbor Belt Railroad as to why strict liability should be applied in this case.

"[3] Indiana Harbor Belt Railroad also argued that a strict liability regime would encourage manufacturers not to ship hazardous materials through densely populated cities and instead choose alternate routes.

The court therefore held that a shipper of a hazardous chemical by rail is not strictly liable for the consequences of a spill or other accident to the shipment en route.