Palsgraf v. Long Island Railroad Co.
Palsgraf v. Long Island Railroad Co., 248 N. Y. 339, 162 N. E. 99, is a leading case in American tort law on the question of liability to an unforeseeable plaintiff. The case was heard by the New York Court of Appeals, the highest state court in New York; its opinion was written by Chief Judge Benjamin Cardozo. In August 1924, a woman was waiting at a Long Island Rail Road station in Brooklyn while taking her daughters to the beach. Two men attempted to board the train before hers; one dropped a package that exploded, causing a large coin-operated scale on the platform to hit her. After the incident, she began to stammer, and subsequently sued the
About Palsgraf v. Long Island Railroad Co. in brief
Palsgraf v. Long Island Railroad Co., 248 N. Y. 339, 162 N. E. 99, is a leading case in American tort law on the question of liability to an unforeseeable plaintiff. The case was heard by the New York Court of Appeals, the highest state court in New York; its opinion was written by Chief Judge Benjamin Cardozo, a leading figure in the development of American common law. The original jury verdict was overturned, and the railroad won the case. The court ruled that there was no negligence because the employees, in helping the man board, did not have a duty of care to Pals graf as injury to her was not a foreseeable harm from aiding a man with a package. The decision has been widely accepted in American law and is taught to most if not all American law students in torts class. In the U.S. many states have taken the approach championed by the Court of appeals’ dissenter, Judge William S. Andrews, in dealing with proximate cause, and have not required that the plaintiff show that the duty owed was to her. The ruling was appealed to the Supreme Court of New York, which ruled in favor of the railroad in October 1928. In May 1927 she obtained a jury verdict of USD 6,000, which the railroad appealed. In August 1924, a woman was waiting at a Long Island Rail Road station in Brooklyn while taking her daughters to the beach. Two men attempted to board the train before hers; one dropped a package that exploded, causing a large coin-operated scale on the platform to hit her.
After the incident, she began to stammer, and subsequently sued the railroad, arguing that its employees had been negligent while assisting the man, and that she had been harmed by the neglect. No one was hurt enough to spend the night in the hospital, though several people, PalsGraf among them, were listed as injured. She had not recovered from the trauma of the events at East New York station at the time of the trial, and her doctor testified at trial that it was due to the events of the incident that she developed a badstammer. The incident was never made clear in the trial or in the opinions of the judges who ruled on the case, but the distance from the explosion to the scale was described in the Times as more than ten feet away. There was speculation that the package was being taken for use at an Italian-American celebration of some sort; no great effort was made to identify the owner. Under New York precedent, the usual duty of utmost care that the railroad as a common carrier owed its customers did not apply to platforms and other parts of the station. The case made the bizarre facts and Cardozo’s outstanding reputation, made the case prominent in the legal profession, and it remains so, taught to many if not many American law student in tort class. Palsgraf’s injury was listed in The New York Times as shock; she also suffered bruising.
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