Palsgraf v. Long Island Railroad Co.
| Palsgraf v. Long Island Railroad Co. | |
|---|---|
 |
|
| Court | New York Court of Appeals |
| Full case name | Helen Palsgraf v. The Long Island Railroad Company |
| Argued | February 24 1928 |
| Decided | May 29 1928 |
| Citation(s) | 248 N.Y. 339; 162 N.E. 99; 1928 N.Y. LEXIS 1269; 59 A.L.R. 1253 |
| Case history | |
| Prior action(s) | Judgment for plaintiff, Kings County Supreme Court, May 31, 1927; reversed, 222 A.D. 166 (N.Y. App. Div. 1927) |
| Holding | |
| 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. | |
| Court membership | |
| Chief Judge | Benjamin Cardozo |
| Associate Judges | Cuthbert W. Pound, William S. Andrews, Frederick Crane, Irving Lehman, Henry Kellogg, John F. O'Brien |
| Case opinions | |
| Majority | Cardozo, joined by Pound, Lehman, Kellogg |
| Dissent | Andrews, joined by Crane, O'Brien |
Palsgraf v. Long Island Railroad Co., 248 N.Y. 339, 162 N.E. 99 (N.Y. 1928), was a decision by the New York Court of Appeals, the highest state court in New York, 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 decision in tort law that helped establish the concept of proximate cause, a limitation of negligence with respect to scope of liability.
The events in this case took place at the East New York Long Island Rail Road station on Atlantic Avenue. A passenger carrying a package, while hurrying to catch and board a moving LIRR train, appeared to two of the railroad's (the appellant, originally defendant) employees to be falling. The employees were guards, one of whom was located on the car, the other of whom was located on the platform. The guard on the car attempted to pull the passenger into the car and the guard on the platform attempted to push him into the car from behind.
The guards' efforts to aid the passenger caused the passenger to drop the package he was holding onto the rails. Unbeknownst to the guards, the package, which was approximately 15 inches long and wrapped in newspaper, contained fireworks, and the package exploded when it hit the rails. 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 (the respondent, originally plaintiff).
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