Palsgraf v. Long Island Railroad Co. – Case Brief Summary

Palsgraf v. Long Island R.R. Co., Ct. of App. of N.Y., 248 N.Y. 339, 162 N.E. 99 (N.Y. 1928).

Facts

Mrs. Palsgraf (P) was standing on a Long Island Railroad (D) train platform when two men ran to catch a train. The second man was carrying a small package containing fireworks. He was helped aboard the train by one guard on the platform and another on the train. The man dropped the package which exploded when it hit the tracks. The shock of the explosion caused scales at the other end of the platform many feet away to fall, striking and injuring Palsgraf. Palsgraf brought a personal injury lawsuit against Long Island Railroad and the railroad appealed the court’s judgment in favor of Palsgraf. The judgment was affirmed on appeal and Long Island Railroad appealed.

Issues

  1. How is the duty of due care that is owed determined?
  2. To whom does a party owe the duty of due care?

Holding and Rule (Cardozo – “Zone of Danger” rule)

  1. A duty that is owed must be determined from the risk that can reasonably be foreseen under the circumstances.
  2. A defendant owes a duty of care only to those who are in the reasonably foreseeable zone of danger.

The court held that the conduct of Long Island Railroad’s guard was wrongful in relation to the man carrying the parcel, but not in relation to Palsgraf standing far away. No one was on notice that the package contained fireworks which when dropped could harm a person as far from the zone of danger as Palsgraf.

To find negligence there must first be a finding that a duty was owed and breached, and that the injury could have been avoided if the defendant had been following that duty. The orbit of the danger or risk associated with a danger or risk is that which a reasonable person would foresee.

Even if the guard had intentionally taken the package and thrown it he would not have threatened Palsgraf’s safety from the appearances of the circumstances to a reasonable person. Long Island Railroad’s liability for an inadvertent or unintentional act cannot be greater than it would be if the act had been intentional.

Disposition

Reversed – judgment for Long Island Railroad.

Dissent (Andrews)

Everyone owes the world at large the duty of refraining from acts that may unreasonably threaten the safety of others. In determining proximate cause the court must ask whether there was a natural and continuous sequence between the cause and effect and not whether the act would reasonably be expected to injure another. The court must consider that the greater the distance between the cause and the effect in time and space, the greater the likelihood that other causes intervene to affect the result. In this case there was no remoteness in time and little in space. Injury in some form was probable.

Notes

The majority adopted the principle that negligent conduct resulting in injury will lead to liability only if the actor could have reasonably foreseen that the conduct would cause the injury. In a 4-3 opinion by Cardozo, the court held that the Long Island Railroad attendants could not have foreseen the possibility of injury to Palsgraf and therefore did not breach any duty to her. Andrews asserted that the duty to exercise care is owed to all, and thus a negligent act will subject the actor to liability to all persons proximately harmed by it, whether or not the harm is foreseeable. Both opinions have been widely cited to support the two views expressed in them.

The reasoning in this case was that Long Island Railroad did not owe a duty of care to Palsgraf insofar as the package was concerned. Cardozo did not reach the issue of “proximate cause” for which the case is often cited. There is no general principle that a railroad owes no duty to persons on station platforms not in immediate proximity to the tracks, as would have been the case if Palsgraf had been injured by objects falling from a passing train.

See Hadley v. Baxendale for a law school contracts case brief involving an issue of foreseeability in a lawsuit for breach of contract.


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