Palsgraf v. Long Island Railroad Co. [1928]

248 N.Y. 339 (1928) · New York Court of Appeals · New York, United States

Summary

Canonical duty and proximate cause case.

Facts

Railroad employees helped a passenger board, dislodging a package of fireworks that injured Helen Palsgraf far away.

Issue

Was the railroad liable to an unforeseeable plaintiff?

Held

No. The risk to Palsgraf was not reasonably foreseeable.

Ratio Decidendi

Negligence liability requires a duty to the plaintiff based on foreseeable risk.

Obiter Dicta

Judge Andrews argued duty is owed to the world, with proximate cause limiting liability.

Reasoning

Duty is relational and owed to foreseeable plaintiffs within the zone of danger.

Significance

Canonical duty and proximate cause case.

Related Cases

No related cases listed.

Exam Tips

Review the ratio and reasoning before applying this case in problem questions.

Sources