Palsgraf v. Long Island Railroad Co.

Brief Fact Summary.

Ms. Palsgraf was struck by railroad scales when a man’s package of fireworks dropped and exploded while he was struggling to get on a moving train.

Synopsis of Rule of Law.

A defendant’s duty is limited to that risk which can be reasonably foreseen within a range of apprehension.

Facts.

Ms. Palsgraf was standing on a platform of Long Island Railroad Co. Two men ran to catch a moving train. One man caught the train, and the other dropped the package he was carrying while guards attempted to help him jump aboard. It turns out that the package contained fireworks that exploded upon falling to the ground, which then caused railroad scales to strike Ms. Palsgraf.

Issue.

If railroad guards push a man onto a moving train and cause that man’s package to explode, may the railroad company be held liable for the guards’ negligence to a plaintiff who sustained injuries while she stood on a nearby platform?

Held.

Reversed with complaint dismissed.

No. The railroad company cannot be held liable for injuries sustained by a plaintiff standing on a nearby platform because she has no cause of action against the railroad guards for the wrongdoing of the man carrying the package.

Dissent.

Justice Andrews

The issue here revolves around proximate cause and not negligence.

The majority held that negligence cannot exist without a duty that is owed to the plaintiff and not others. Andrews disagrees, arguing that negligence exists whether damage does or does not result if there is an unreasonable act and others may be affected by the unreasonable act.

Everyone owes a duty to the world to refrain from acts that unreasonably threaten the safety of others, regardless of the individuals injured would generally be thought to be in the danger zone.

It doesn’t matter that the damages are unusual, unexpected, unforeseen, or unforeseeable as long as the negligence was the proximate cause of the damages. Proximate cause is never exact and as a matter of policy is cut off at a certain, arbitrary line to give only a rough estimate of justice. In determining proximate cause, courts should consider whether there was:

A natural and continuous sequence between the cause and the effect;
A substantial factor in producing the effect; and
A direct connection between the two without too many intervening causes.

Here, given an explosion, the danger zone could reasonably be expanded to the entire platform because, except for the explosion, Ms. Palsgraf would not have been injured.

Discussion.

Ms. Palsgraf’s claims are limited to intentional invasion of bodily security and unintentional invasion by conduct that a reasonable person would find hazardous. Here, there was no intentional invasion and the hazard was not apparent to the reasonable person because the package’s appearance did not indicate that it was filled with fireworks. Thus, if anything, the wrong done by the railroad guard was not a wrong in relation to Ms. Palsgraf, but rather the man who was carrying the package.

It is unlikely that any wrong was done to the man carrying the package, as the guard’s acts were to stabilize the man’s jump onto the train and make him safe. If anything, the wrong was to the man’s property only in failing to keep the package safe.

A person who jostles another person who is holding a bomb in the center of a crowd does not invade the rights of individuals who stand at the fringe of the crowd, even if the unintended jostling causes the explosion of the bomb. Similarly, in standing across the platform, Ms. Palsgraf could recover against the man who carried the package, but not the guards whose unintended contact caused the package to explode.

A defendant’s duty is limited to that risk which can be reasonably foreseen within a range of apprehension. Some acts are inherently dangerous (e.g., shooting into a crowd of people) and provide for transferred intent when an act willfully dangerous to Person 1 actually results in injury to Person 2. However, there was nothing in this situation to suggest that the package contained fireworks, so there is no issue of causation in this case.