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MATTER OF JOHNS-MANVILLE ASBESTOSIS CASES
516 F.Supp. 375 (1981)
United States District Court, N. D. Illinois, E. D.
May 15, 1981.


 

 

Indeed, that construction is fully consistent with the use of the term "right," which in both Hohfeldian and common usage attaches to a party asserting, not a party defending, a claim. Just as the term "liability" refers to obligations owed by the dissolved corporation, so "right or claim" must refer to obligations owed to that corporation. In each instance the term relates to the dissolved corporation itself, not to its adversary.4
Thus Singer & Talcott retains its full vigor as to post-dissolution liabilities of a corporation. And in those terms it spoke in terms of "those whose rights had accrued against the corporation ..." (emphasis added). That language in turn invokes the concept of "accrual" of indemnification actions, which as already discussed is fatal to Hooker's claims.
This Court's reading of Section 94 is supported by the most recent Illinois decision applying the statute. In Blankenship v. Demmler Mfg. Co.,89 Ill.App.3d 569, 44 Ill.Dec. 487, 411 N.E.2d 1153 (1st Dist. 1980) plaintiff had purchased a machine from the corporate defendant before its dissolution but brought a strict liability action for an injury that occurred more than two years after dissolution. Plaintiff's claim was rejected, 89 Ill.App.3d at 574, 411 N.E.2d at 1156-57:
Since a cause of action based on strict liability accrues at the time of the injury [citation omitted], the time period provided in the survival statute had expired several years before the plaintiff's claim
[ 516 F.Supp. 378 ]

even arose. In the absence of a statute permitting a cause of action which accrues after dissolution to be brought against a dissolved corporation, plaintiff has no valid cause of action ...
Like the purchase of a defective machine in Blankenship, plaintiffs' actions against Hooker in the Asbestosis Cases present only a potential injury. North American cannot incur any liability until it is first known whether Hooker's indemnity action will accrue. Accordingly Hooker's claims against North American must be dismissed.

Cassiar

Cassiar contends that under the Illinois contribution statute (Ill.Rev.Stat. ch. 70, §§ 301 et seq.) an action for contribution accrues before any judgment has been entered:


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