Palsgraf v. Long Island Railroad

Brief Fact Summary.

While a passenger trying to jump aboard, he dropped a package which contained fireworks and exploded. The explosion caused some scales to fall and hit Plaintiff.

Synopsis of Rule of Law.

If defendant commits a negligent act, defendant would be liable for that risk of some foreseeable result, but generally not liable for an entirely different, unforeseeable result.

Facts.

Plaintiff was standing on a platform owned by defendant waiting for her train. There were two men running to catch another train as it was moving away from the station. One of the men had difficulty hopping on the train and two guards helped him. However, as he was getting on the train, his package dropped on the track. The package was small and covered by newspaper, but it actually contained firework and exploded. The shock of the explosion caused several scales to dislodge and injured plaintiff.

Issue.

Whether the guards were negligent for failing to protect a bystander’s bodily security?

Held.

No. The judgment of the appellate division and the trial court was reversed.

Dissent.

Justice Andrews

Justice Andrews interpreted the duty of care very broadly. He believed that if therewas an unreasonable act, and someone might be affected, then there was negligence. This means, if an act itself is wrongful, it is a wrong to the public at large, not only to those who happen to be within the radius of danger.

Discussion.

Negligence is not actionable unless it involves the invasion of a legally protected interest, the violation of a right. The majority does not agree with the “negligence in the air” idea and alleged that negligence and duty are correlative. If no hazard is apparent to the eye of ordinary vigilance, an innoncent act is not a tort if it just happens to injure plaintiff.

In this case, the conduct of the guard was not a wrong in its relation to plaintiff, who was a bystander far away from the guard. The guard had no way to know that the falling package was explosive and could hurt plaintiff, thus the guard owed no duty to plaintiff. The explosion was the proximate cause of plaintiff’s injury and the guard could not have reasonably foreseen such a disaster by exercising ordinary care.