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Palsgraf v Long Island Railroad Co

Tort Law

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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.

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