Palsgraf v. Long Island R.R. Co.

Brief Fact Summary.

A railway guard employed by the Defendant, the Long Island R.R. Co. (Defendant), caused a man to drop a package of fireworks upon the tracks. The fireworks caused an explosion and the force of the explosion caused a scale at the other end of the station to fall on the Plaintiff, Ms. Palsgraf (Plaintiff) and injure her.

Synopsis of Rule of Law.

A negligent party only owes a duty to the party who was directly wronged by them.

Facts.

While waiting on the platform of the Defendant’s train station for her train to arrive, the Plaintiff was struck and injured when the station’s large scales fell on her. The scales fell when a large explosion occurred. The explosion was the result of a package of fireworks hitting the rails. The man carrying the package dropped the fireworks when he was assisted onto a moving train by one of the train guards.

Issue.

Whether the Defendant’s negligence was a proximate cause of the Plaintiff’s injury.

Held.

When the Defendant’s guard attempted to assist the man with the package onto the train, the guard committed an act of harm on the man. The Plaintiff, on the other had, was several feet away and there was no warning that the guard’s action could harm a person standing on the opposite side of the rail platform. The guard’s actions did not violate a right or an interest of the Plaintiff’s and so the Defendant owes no duty to the Plaintiff because the wrong was not done to her, but to another.

Dissent.

The theory of negligence posed by the dissent looks not at the duty, but at the proximate cause of the injury to the Plaintiff. If an act unreasonably threatens the safety of others, the party responsible for the act is liable for all of the proximate consequences, even if they are outside of the “orbit” of danger. The dissent points out that limiting the legal duty owed by the Defendant to just the man entering the train and not the other passengers is too narrow. Some wrongs are to the public at large because due care is a duty imposed on all of society to protect each other from unnecessary danger. If an unreasonable risk is taken, then its consequences are not confined to individuals.

Discussion.

The “orbit” of the duty here is the “orbit” of foreseeability. The defendant’s guard was negligent when he dislodged the package from the man carrying the fireworks. It was not foreseeable that this act could cause injury to the Plaintiff, who was several feet away from the initial injury. The guard owed no duty of care to the people on the platform generally, and could not have known the nature of the contents of the package. The harm to the Plaintiff was the unforeseeable result of harm caused to another person. Furthermore, by dislodging the package from the man’s arms, the guard could not have expected the harm to carry a risk to people standing several feet away on the platform. The plaintiff cannot predicate her injury upon the wrong done to someone else. The duty the Defendant owed is defined by the risk reasonably perceived. The reasonable person would not perceive that the risk created by dislodging a package while attempting to help a passenger onto a train would carry with it a duty to persons several feet away.