Palsgraf v. Long Island Railroad Co. [1928]
248 N.Y. 339 (1928) · New York Court of Appeals · New York, United States
Issue
Was the railroad liable to an unforeseeable plaintiff?
Held
No. The risk to Palsgraf was not reasonably foreseeable.
Exam use
Review the ratio and reasoning before applying this case in problem questions.
Summary
Canonical duty and proximate cause case.
Facts
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
Essay-Ready Explanation Generator
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Reference to Palsgraf v. Long Island Railroad Co. (248 N.Y. 339 (1928)) strengthens a tort law answer because the case reflects the principle that Negligence liability requires a duty to the plaintiff based on foreseeable risk. Applied to a problem question, the case should be used after identifying the issue as Was the railroad liable to an unforeseeable plaintiff? The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.
Significance
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Exam Tips
Revision Checklist
- Name the issue before discussing facts so the marker sees the legal question immediately.
- State the holding in one sentence, then use the ratio to explain why the court reached that result.
- Use the citation and jurisdiction to show why this authority matters for the problem you are answering.
- Pair this case with one supporting or contrasting authority if the question tests limits, policy, or exceptions.