| Palsgraf v. Long Island Railroad Co. | |
|---|---|
 | |
| Court | New York Court of Appeals |
| Full case name | Helen Palsgraf v. The Long Island Railroad Company |
| Argued | February 24, 1928 |
| Decided | May 29, 1928 |
| Citation | 248 N.Y. 339; 162 N.E. 99; 1928 N.Y. LEXIS 1269; 59 A.L.R. 1253 |
| Case history | |
| Prior history | Judgment to plaintiff for $6,000 and costs, Kings County Supreme Court, May 31, 1927 (Burt Jay Humphrey, J.); affirmed, 222 A.D. 166, 25 N.Y.S. 412 (App. Div. 1927) |
| Subsequent history | Reargument denied, 249 N.Y. 511, 164 N.E. 564 (1928) |
| Holding | |
| 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. | |
| Court membership | |
| Chief judge | Benjamin Cardozo |
| Associate judges | Cuthbert W. Pound, William S. Andrews, Frederick Crane, Irving Lehman, Henry Kellogg, John F. O'Brien |
| Case opinions | |
| Majority | Cardozo, joined by Pound, Lehman, Kellogg |
| Dissent | Andrews, joined by Crane, O'Brien |
Palsgraf v. Long Island Railroad Co., 248 N.Y. 339, 162 N.E. 99 (1928), 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 and later a United States Supreme Court justice.
The plaintiff, Helen Palsgraf, was waiting at a Long Island Rail Road station in August 1924 while taking her daughters to the beach. Two men attempted to board the train before hers; one (aided by railroad employees) 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. In May 1927 she obtained a jury verdict of $6,000, which the railroad appealed. Palsgraf gained a 3–2 decision in the Appellate Division, and the railroad appealed again. Cardozo wrote for a 4–3 majority of the Court of Appeals, ruling that there was no negligence because the employees, in helping the man board, did not breach any duty of care to Palsgraf as injury to her was not a foreseeable harm from aiding a man with a package. The original jury verdict was overturned, and the railroad won the case.
A number of factors, including the bizarre facts and Cardozo's outstanding reputation, made the case prominent in the legal profession, and it remains so, taught to most if not all American law students in torts class. Cardozo's conception, that tort liability can only occur when a defendant breaches a duty of care the defendant owes to a plaintiff, causing the injury sued for, has been widely accepted in American law. In dealing with proximate cause, many states have taken the approach championed by the Court of Appeals' dissenter in Palsgraf, Judge William S. Andrews.