Palsgraf v. Long Island Railroad Co.
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| Palsgraf v. Long Island Railroad Co. | ||||||||
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| Missing image NY_COA_seal.jpg New York Court of Appeals | ||||||||
| 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 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.
A man carrying fireworks wrapped in newspaper was trying to board a leaving train. When a railroad guard tried to give him a helpful push aboard, the man dropped the fireworks, which exploded. Helen Palsgraf was standing at the other end of the platform and was injured when scales that were dislodged by the explosion fell on her. She then sued the guard's employer for causing her injuries. Palsgraf won a verdict at trial, which was then affirmed by the Appellate Division.
The Court of Appeals reversed, however, 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 or not 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.
The three-judge dissent, 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."
Since Palsgraf, the ostensibly conflicting views between the majority and the dissent have been resolved, and foreseeability is 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.
Palsgraf is standard reading for first-year tort students in American law schools.