Palsgraf v. Long Island Railroad Co.

Brief Fact Summary.

Palsgraf (Plaintiff) was standing on the platform of Long Island Railroad Co. (Defendant) when another passenger’s package exploded and caused some scales to tip over and hit Plaintiff.

Synopsis of Rule of Law.

A person cannot be held liable for harm that is not of the type that would be foreseeable.

Facts.

Palsgraf (Plaintiff) stood on the train platform owned by the Long Island Railroad Co. (Defendant), having just bought a ticket. A man who was carrying a package wrapped in newspaper began running to catch the train. He required assistance from guards on the train and platform to get onto the train. As he was getting on, the package (which contained fireworks) fell from his arms onto the tracks and exploded. The explosion caused a scale to fall over and injure Plaintiff.

Issue.

Can a defendant be held liable for harm when it was not of the same type as the harm that would be foreseeable?

Held.

No, the Court held a defendant cannot be held liable for harm that is of a different type than that which was foreseeable.

Dissent.

Justice J. Andrews

The dissent construed the idea of duty much more broadly, believing everyone owes everyone else a duty when their actions could threaten others. J. Andrews argued that proximate cause is arbitrary and difficult to determine. He stated that proximate cause is determined through a combination of “convenience, of public policy, of a rough sense of justice”.

Concurrence.

a

Discussion.

The Court concluded that Defendant could not be liable because there was no duty to Plaintiff, rather than because the action was not the proximate cause of Plaintiff’s injuries. There was no duty to Plaintiff because she was far from the initial action leading to the chain of events that harmed her, much like a person on the outside of a crowded area where a ripple effect from a shove in the center leads to the person being jostled. While the falling scales interfered with Plaintiff’s bodily security, the type of harm that was foreseeable was harm to property.