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Palsgraf v. Long Island Railroad Co.

Citation. 162 N.E. 99 (N.Y. 1928)
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Brief Fact Summary.

A woman was injured after fireworks fell under a train and exploded.

Synopsis of Rule of Law.

A claim of negligence is not actionable if it did not invade a legally protected interest of the plaintiff.


The plaintiff was at a train station, waiting for her train.  While she waited, another train began to pull out of the station.  Two men were hurrying to catch it while it was already moving, and jumped on board.  The first man made it, but the second nearly didn’t, but a guard on the train grabbed him and got him in.  As he did so, a package the man was carrying fell, and was run over.  It exploded because it contained fireworks, and the blast knocked over the scales at the other end of the station, injuring the plaintiff.


Was the defendants claim of negligence by the defendant actionable?


No, because there was not proximate cause between the invasion of the plaintiff’s legally protected interest and the defendant’s potentially negligent actions.


Justice Andrews, J.

The justice dissents because he feels this ought to be a question for a trier of fact, such as a jury.  He opines that the duties are owed generally, and therefore the fact specific inquiry should be allowed to proceed.


The court found that the claim of negligence was not actionable because there was not proximate cause.  The plaintiff, it is conceded, has a legally protected interest in her bodily security while standing on the platform in the station.  However, thee court found that the package that exploded had no indications of its contents and did not seem anything other than harmless.  The defendant, in acting, was not running a foreseeable risk of injury to the plaintiff.  These were extraordinary circumstances, and the defendant’s actions were not the proximate cause of the plaintiffs injuries.

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