Palsgraf v. Long Island Railroad Co. – (Unforseeable Consequences)
Name: Helen Palsgraf, Respondent v. The Long Island Railroad Company, Appellant
Court: U.S. Supreme Court
Judicial History: The Long Island Railroad Company appeals from a judgment of the Appellate Division of the Supreme Court in the Second Judicial Department in 1927 for damages on a negligence theory of liability awarded to Helen Palsgraf.
Facts: Hellen Palsgraf was standing on a train platform near some scales after having purchased a train ticket and was waiting to board her scheduled train. At that time a train was departing and two men ran to board. The first man boarded without incident and the second had to jump and seemed unsteady enough to cause a guard aboard the train to pull him aboard and at the same time a guard on the platform to push him aboard. During the boarding incident the man dropped a nondescript package he was carrying. The package happened to contain fireworks and the fireworks exploded upon hitting the ground. The explosion caused the scales under which Hellen Palsgraf was standing to fall and in falling they struck Palsgraf and injured her. Palsgraf sued for damages and won in a lower court. The Railroad Company appeals this judgment.
Issues: Is foreseeability of type of hazard the determining factor for liability under a negligence theory of breach of duty in this case.
Holdings: Yes, since the type of injury which occurred was not foreseeable, the lack of foreseeability negates any liability based on a negligent breach of duty by the guard on the train.
Reasoning: The reasonable person would not foresee this type of consequence of helping a man onto a train. One the package had no indication of being any type of explosive. The scale was so far removed from the guard, the man and the fallen package that this type of consequence was completely unforeseeable.
Decision: Judgment Reversed, complaint dismissed, with costs in all courts.
Majority Opinion: Delivered by Justice Cardozo, with which Pound, Lehman, and Kellogg, JJ concur. Cardozo takes a narrow view of duty and limits it to plaintiffs in the foreseeable zone of danger. Cardozo in his opinion states, “The conduct of the defendant’s guard, if a wrong in its relation to the holder of the package, was not a wrong in its relation to the plaintiff, standing far away. Relatively to her it was not negligence at all.”
Dissenting Opinion: Delivered by Justice Andrews, with which Crane and O’Brien, JJ concur. In this dissent the famous “Andrews view of Duty” is given its inception. In addressing the issues of duty, proximate cause and negligence, Justice Andrews took a broader view that a duty to care must be extended to anybody who is injured because of a series of events set in motion by an act deemed to be the proximate cause of the injury. Andrews states, “We deal in terms of proximate cause, not of negligence.” He goes on to say, “Due care is a duty imposed on each one of us to protect society from unnecessary danger, not to protect A, B, or C alone.” The Andrews view of duty is encapsulated I his own words, “Not only is he wronged to whom harm might reasonably be expected to result, but he also who is in fact injured, even if he be outside what would generally be thought the danger zone.”