Palsgraf v. Long Island R. Co.

FACTS:
Palsgraf, plaintiff, was standing on a platform owned by the Long Island Railroad Company, defendant,
waiting for the train to Rockaway Beach. At this time, another train bound for a different location
stopped at the platform and two men raced to board it. The train began to slow down and the first man
jumped onto the train successfully, while the other, who carried a package, had difficulty boarding. In
turn, two of the defendant’s employees assisted him by pushing and pulling him onto the train. As a
result, the man dropped his package, which contained fireworks (unknown by any other party). The
package fell onto the rails and exploded, resulting in dislodgment of multiple scales at the other end of
the platform station. A few of the dislodged scales then struck and injured the plaintiff. Accordingly, the
plaintiff brings an action of suit for negligence against the defendant railroad. The trial court issued a
judgment in favor of the plaintiff, which the defendant appealed. The appellate court affirmed the
decision and now the defendant appeals once again.
ISSUE:
Whether a defendant may be held liable for injury caused to a plaintiff that is not reasonably
foreseeable.
RULE:
If a defendant owes a legal duty to the plaintiff, breaches that duty, and the resulting injury was
reasonably foreseeable, then proximate cause is established and the defendant is liable for negligence.
ANALYSIS:
First off, Judge Cardozo delivers the majority opinion of the court. Palsgraf, the plaintiff, received
injuries while awaiting a train on a platform owned by the defendant because a third party failed to
secure his bag, which contained fireworks, while jumping onboard of a departing train resulting in the
explosion of the fireworks. In this case, the defendant’s employee grabbed the man, who held the
package of fireworks, to assist him board the departing train. The employee did not have knowledge of
the dangerous items within the package when he threw it to the third party. In other words, the conduct
of the employee cannot be construed as an unlawful or wrongful act putting other people, including the
plaintiff, in any foreseeable harm. The defendant would only be held liable for negligence and the harm
done to the plaintiff if the harm was a reasonably foreseeable consequence of potential negligence on
the part of the defendant or their employee(s). No possible connection may be drawn between the
plaintiff’s injury and the railroad employee’s actions. Therefore, the defendant did not breach their duty
of reasonable care to the plaintiff because the resulting harm was not a reasonably foreseeable
consequence of the employee’s attempt to help the third party get onto the train. In fact, the only person
able to claim negligence against the defendant would be the third party, as injury to his property did
indeed occur due to conduct of the defendant’s employee. Therefore, the judgment in favor of the
plaintiff should not be upheld because the plaintiff’s injury was not a reasonably foreseeable
consequence of the defendant employee’s actions.
On the other hand, the dissenting opinion, given by Judge Andrews, contends that the railroad
employee’s actions, i.e. helping the man carrying fireworks board the train, directly caused the package
to fall and, therefore, cause the harm to the plaintiff. Liability for negligence arises when one’s conduct
or omission unreasonably harms the rights of others or unreasonably fails to protect from the resulting
dangers caused by the wrongful conduct. Andrews posits that two elements must be met: (1) There was
an act or omission, and (2) there was a right. In his opinion, it is incorrect to say that one only has a
duty of reasonable care to protect certain persons from the consequences of an unlawful/wrongful act.
Instead, one has both the legal duty to protect persons in the “zone of danger” from harmful acts, and
the duty to protect society in general. In this case, the injured party represented a member of the public
harmed by the consequence of a potentially negligent act of the defendant’s employee. To prove that
the defendant is liable for negligence to the plaintiff, proximate cause must be established. Here, there
was a natural and continuous series of events leading to the plaintiff’s injury. There was also little to no
remoteness in time or space between the act and injury that could introduce the possibility of an
intervening force that could have caused the plaintiff’s injury. Therefore, as a matter of law, Andrews
cannot say that the plaintiff’s injuries were not the proximate consequence of the employee’s negligent
conduct and, therefore, the judgment should be affirmed in favor of the plaintiff.
CONCLUSION:
The Court of Appeals of New York reversed the trial court and appellate court judgments in favor of the
plaintiff, thereby holding in favor of the defendant.