Palsgraf vs' Long Island Railroad Co'

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Palsgraf vs. Long Island Railroad Co.

• Court of Appeals of New York, 1928
• 248 N.Y. 339, 162 N.E.99

By Leanna Holmes, Yuka Okabe, Nazariy Gural,
Matt Brown
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Facts

• Who
• Plaintiff Helen Palsgraf
• Defendant Long Island Railroad Company
• What
• Injured by falling object after fireworks
  explosion
• Where
• Long Island Railroad train platform, New York

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Timeline

• Palsgraf was buying a ticket on railroad
  platform.
• As a train stopped at the station, two men ran to
  catch it.
• One was safely on, the other jumped onto the
  moving car, but started to fall.
• Two guards helped the man regain his balance, but
  in doing so, they knocked a small package from
  his arm.
• The package contained fireworks, and fell onto
  the rails and exploded.

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Timeline Cont.

• The explosion caused a scale to fall over,
  landing on Mrs. Palsgraf, injuring her.
• Palsgraf brings suit against LIRR for injuries.
• LIRR appealed decision from trial and appellate
  courts decisions in favor of Palsgraf.
• The judgment for Palsgraf was reversed.

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Points of View

• Palsgraf The injury was caused by the guards
  negligence.
• Long Island Railroad The guard was just helping
  the passenger board the train, and no reasonable
  person would have expected the falling package to
  contain fireworks.

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Other Points of View

• Victims of freak accidents This could
  determine whether or not they could sue for
  negligence in an unusual event.
• Carriers Might have to start putting warning
  labels on all packages that contain explosive or
  flammable materials.

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Issue

• Could the action be transferred to negligence and
  proximate cause of injury to Mrs. Palsgraf?

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Concepts

• Negligence The omission to do something which a
  reasonable person, guided by those ordinary
  considerations which ordinarily regulate human
  affairs, would do, or the doing of something
  which a reasonable and prudent person would not
  do.
• Proximate cause Where the act or omission played
  a substantial part in bringing about or actually
  causing the injury or damage, and where the
  injury or damage was either a direct result or a
  reasonably probable consequence of the act or
  omission.
• Unforeseeable consequences even if the
  defendants negligent conduct is a cause in fact
  of harm to the plaintiff, the conduct is not a
  proximate cause unless the defendant could
  reasonable have anticipated injuring the
  plaintiff or a class of persons of which the
  plaintiff is a member.

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Interpretation

• The Court of Appeals of NY decided that Palsgraf
  had no case against LIRR because no negligence
  occurred relative to her. She was too far away
  for anyone to anticipate her being injured, and
  the guards had no way of knowing they would knock
  the package away from the man, or what was in
  that package. Palsgraf was far removed from
  what happened, so this is not Long Islands
  negligence.

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Implication

• The Palsgraf case made it clear that when the
  defendant could not have foreseen injuring the
  plaintiff or a class of persons to which the
  plaintiff belonged, he or she is not liable.
  Therefore, people cannot be sued for causing
  injury to a person or class that wasnt even
  nearby or they had no way of knowing would be
  affected.

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Related Cases

• Court of Appeals of New York
• Paul v. Consolidated Fireworks Co. of America
• June 9, 1914
• Court of Appeals of New York
• Adams v. Bullock
• November 18, 1919