Fed. R. Civ. P. 12(b)(6) is designed to screen out cases where a complaint states a claim based upon a wrong for which there is clearly no remedy, or a claim which the plaintiff is without right or power to assert and for which no relief could possibly be granted.
In a case stemming from a terrorist detonation of an explosive device under the World Trade Center on February 26, 1993, plaintiff owners sued defendants, the manufacturers of fertilizer products, on theories of negligence and products liability, based on the terrorists' alleged use of the manufacturers' fertilizer products in construction of the explosive device. The District Court dismissed the negligence and products liability claims based on failure to state claim upon which relief could be granted pursuant to Fed. R. Civ. P. 12(b)(6).
Was the District Court's dismissal proper?
The court upheld the district court's dismissal under Fed. R. Civ. P. 12(b)(6) for failure to state a claim upon which relief could be granted. The court found that plaintiff's complaint failed to establish the existence of a duty owed by defendants, as the manufacturers of raw materials that were not themselves dangerous had no duty to prevent the buyer from incorporating the materials into another part that could be dangerous. Alternatively, proximate cause was not established, as the terrorists' actions were superseding and intervening events breaking the chain of causation.