Illinois Central Gulf Railroad v. R.R. Land, Inc.

BARKSDALE, Circuit Judge:

The pivotal issue before us concerns the district court’s grant of reformation in favor of Illinois Central Gulf Railroad Company (IC). Because we conclude that the contractual negligence defense does not bar reformation where mutual mistake has been pleaded and proved, and that the district court did not clearly err in finding both clear proof of an antecedent agreement and clear and convincing evidence of mutual mistake in reducing that agreement to writing, we AFFIRM the grant of reformation. We also AFFIRM the district court’s rejection of claims for damages by…