Palsgraf v. Long Island Railroad Co.
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| Palsgraf v. Long Island Railroad Co. | ||||||||
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 New York Court of Appeals |
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| Argued February 24, 1928 Decided May 29, 1928 |
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| Defendant could not be held liable for an injury that could not be reasonably foreseen. New York Supreme Court, Appellate Division, reversed and complaint dismissed. | ||||||||
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Palsgraf v. Long Island Railroad Co., 162 N.E. 99 (N.Y. 1928), was a decision by the New York Court of Appeals (the highest court in the state) written by Chief Judge Benjamin Cardozo, a leading figure in the development of American common law and later a Supreme Court justice. Palsgraf is a landmark in tort law that helped establish the limitations of negligence.
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[edit] Facts
A passenger carrying a package, while hurrying to catch and board a moving train, appeared to the Railroad's (Defendant's) employee to be falling. The employee attempted to help the passenger and caused a package the passenger was holding to fall on the rails. Unbeknownst to the employee, the package contained fireworks, and the employee's effort to help caused the package to explode. The shock reportedly knocked down scales at the other end of the platform (although later accounts suggest that a panicking bystander may have upset the scale), which injured Mrs. Helen Palsgraf (Plaintiff). Palsgraf sued the Railroad, claiming her injury resulted from negligent acts of the employee. The court found for Palsgraf (Plaintiff) by verdict from a jury, Long Island Railroad appealed the judgment.
[edit] Opinion of the court
The Court of Appeals reversed and dismissed Palsgraf's complaint, deciding that the relationship of the guard's action to Palsgraf's injury was too indirect to make him liable.
Cardozo, writing for three other judges, wrote that there was no way that the guard could have known that the package wrapped in newspaper was dangerous, and that pushing the passenger would thereby cause an explosion. The court wrote that "there was nothing in the situation to suggest to the most cautious mind that the parcel wrapped in newspaper would spread wreckage through the station. If the guard had thrown it down knowingly and willfully, he would not have threatened the plaintiff's safety, so far as appearances could warn him." Without any perception that one's actions could harm someone, there could be no duty towards that person, and therefore no negligence for which to impose liability.
The court also stated that whether the guard had acted negligently to the passenger he pushed was irrelevant for her claim, because the only negligence that a person can sue for is a wrongful act that violates their own rights. Palsgraf could not sue the guard for pushing the other passenger because that act did not violate a duty to her, as is required for liability under a negligence theory. It is not enough for a plaintiff to merely claim an injury. "If the harm was not willful, he must show that the act as to him had possibilities of danger so many and apparent as to entitle him to be protected against the doing of it though the harm was unintended."
This concept of foreseeability in tort law tends to limit liability to the consequences of an act that could reasonably be foreseen rather than every single consequence that follows. Otherwise, liability could be unlimited in scope, as causes never truly cease having effects far removed in time and space.
[edit] Dissenting opinion
The three-judge dissent, written by Judge Andrews, by contrast, saw the case as a matter of proximate cause—Palsgraf's injury could be immediately traced to the wrong committed by the guard, and the fact of the wrong and the fact of the injury should be enough to find negligence.
The dissent took note of recent expansions in New York state tort law, that allowed children to sue for the death of their parents or spouses for loss of consortium, arguing that these expansions were based on the fact of injury beyond the foreseen injury of the deceased, and on the needs of public policy. "What we do mean by the word 'proximate' is, that because of convenience, of public policy, of a rough sense of justice, the law arbitrarily declines to trace a series of events beyond a certain point. This is not logic. It is practical politics."
[edit] Influence of the case
There is still active debate over the two views presented in this case. Most courts adopt Cardozo's approach of rejecting unforseeable plaintiffs at the duty stage of analysis, while others follow Judge Andrews' holding that a duty is owed to all possible plaintiffs, subject to the limits of proximate causation. A third group of courts claim to follow the majority holding, but misinterpret the Cardozo holding to be about proximate causation, which it is not.
Today, however, foreseeability is typically seen as a component of proximate cause that limits how far direct causation will be traced. This may be consistent with the dissent's reasoning that the line should be drawn based on public policy. It is argued that as one of the main goals of tort law is to discourage harmful behavior (in addition to compensating the particular victim), limiting liability to harm that is foreseeable—more likely to occur as a consequence—would more efficiently direct risk avoidance.
While many practitioners long since out of law school remember Palsgraf as a foreseeability (proximate causation) case, its actual significance lies with respect to the duty aspect of negligence, not causation.
Palsgraf is standard reading for first-year tort students in law schools in many jurisdictions.
