Palsgraf v Long Island Railroad Co is a 1928 decision of the New York Court of Appeals, again written by Judge Benjamin Cardozo, that shaped the modern understanding of duty and proximate cause in negligence. A railroad guard helped a passenger board a moving train, dislodging a package of fireworks the passenger carried, which exploded; the shock allegedly caused scales on a distant platform to fall and injure Helen Palsgraf. Cardozo held for the majority that the railroad owed Palsgraf no duty because the harm to her was not a reasonably foreseeable result of the guards conduct, since negligence is a wrong defined in relation to those it could be expected to injure, not a wrong owed to the world at large. The case remains a central teaching text on how far a defendants duty of care extends to unforeseen plaintiffs.
Facts
Decision Year Decision Date HoldingThere was no negligence because the railroad employees, in helping a man board, did not breach any duty of care to Palsgraf, since injury to her was not a foreseeable harm from aiding a man with a package; the original jury verdict for Palsgraf was overturned and the railroad won. 2 Current StatusCardozo's duty-of-care conception, that tort liability requires a breach of a duty the defendant owes to the specific plaintiff, has been widely accepted in American law and remains foundational to negligence doctrine. 2 Case Status
Case Status (category) FAQs
What happened in Palsgraf v Long Island Railroad Co?
A fireworks explosion allegedly toppled scales onto Helen Palsgraf, and the court found no duty was owed.
A railroad guard helped a passenger board a moving train, dislodging a package of fireworks the passenger carried, which exploded. The shock allegedly caused scales on a distant platform to fall and injure Helen Palsgraf. In 1928 the New York Court of Appeals, in an opinion by Judge Benjamin Cardozo, held that the railroad owed her no duty.
Why did Palsgraf lose her negligence claim?
The harm to her was not a foreseeable result of the guard's conduct.
Cardozo held for the majority that harm to her was not a reasonably foreseeable result of the guard's conduct. Negligence is a wrong defined in relation to those it could be expected to injure, not a wrong owed to the world at large, so the original jury verdict for Palsgraf was overturned.
Connections
Authored By
Decided By
Source Palsgraf v. Long Island Railroad Co. (Wikipedia)
In Legal System
In the Other Atlases
Found In
Also in Geography Atlas: where this subject is found.
Sources
1. Wikidata: Palsgraf v Long Island Railroad Co
Source: leading case in American tort law on proximate cause, still followedView the Source 2. Palsgraf v. Long Island Railroad Co. (Wikipedia)
WikipediaLead section, opening sentence
Palsgraf v. Long Island Railroad Co., 248 N.Y. 339, 162 N.E. 99 (1928), is a leading case in American tort law
Lead section, third paragraph
ruling that there was no negligence because the employees, in helping the man board, did not breach any duty of care to Palsgraf as injury to her was not a foreseeable harm from aiding a man with a package. The original jury verdict was overturned, and the railroad won the case.
Lead section, closing paragraph
Cardozo's conception, that tort liability can only occur when a defendant breaches a duty of care the defendant owes to a plaintiff, causing the injury sued for, has been widely accepted in American law.
Infobox, DecideDate field
May 29,
Trial section, filing sentence
Palsgraf brought suit against the railroad in the Supreme Court of New York, Kings County, a trial-level court, in Brooklyn on October 2, 1924.
- Decided By: New York Court of Appeals, Infobox court field: New York Court of Appeals
In Group: Negligence and Strict Liability Tort Cases, Introduction, sentence 1
Palsgraf v. Long Island Railroad Co., 248 N.Y. 339, 162 N.E. 99 (1928), is a leading case in American tort law on the question of liability to an unforeseeable plaintiff.
View the Source Reader Challenges (0)
No disputes yet. Spotted an error or a better source? Open the first one.
Sign in to dispute this or suggest a correction.