Brief 3 Colin Crawford
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Colin Crawford
Palsgraf v. Long Island Railroad Company
248 N.Y. 339, 162 N.E. 99 (1928)
Posture: Plaintiff Helen Palsgraf sued Long Island Railroad Company, claiming the negligence of its railroad employee caused her post-trauma conditions. King County Supreme Court sided with Palsgraf, awarding her $6,000 in addition to recovering $142, pursuant to statute. Defendant
railroad appealed to the Appellate Division of the New York Supreme Court claiming that there was no negligence in assisting a man board a train, and even if there was, negligence was not the direct cause of her injuries. The Appellate Division affirmed the lower court’s decision, holding that negligence was a direct cause of her injuries. A dissent in the appellate division case allowed
the appeal to advance to the New York Court of Appeals.
Facts: In 1924, Helen Palsgraf was standing on a platform at the Long Island Railroad Station. A
train, not hers, arrived. As it began to depart, two men chased after in attempt to board the train. One man made it through the closing doors of the train with no issues, while the other man, holding a package, leapt toward the closing doors with the assistance of a porter shoving him from behind and the train crew pulling him aboard. In the process, the second man dropped his package, and it subsequently exploded as it had contained fireworks. By means of the explosive force or the panicking of those nearby, a coin-operated scale fell onto Palsgraf. Several days after, she developed a stammer and thus sued Long Island Railroad on the grounds that its employees were negligent while assisting the second man, ultimately claiming their negligence caused her post-trauma stammer. The trial court decided in favor of the plaintiff. Upon first appeal by the Long Island Railroad Company, the Supreme Court of New York, Appellate Division affirmed the trial court’s decision in 1927, sharing the belief that the negligent act of the
railroad’s employee caused the explosive package to slip from the second man’s grasp before it exploded. Entitled by law to advance to the New York Court of Appeals given a dissent in the appellate division, the defendant railroad maintained their argument that there was no negligence
because her injury was not a probable consequence of helping the man to board the train.
Issue: Because Palsgraf sustained injuries after the blast of a dropped package, was Long Island Railroad Company liable for negligence if their employee pushed the package-bearing man?
Held: No.
Reasoning & Rationale: Reversing the decision of both lower courts, Chief Judge Cardozo of the New York Court of Appeals delivered the majority opinion in a 4-3 decision that the action by the railroad employee could not be considered negligent as it relates to Palsgraf because they could not reasonably predict that their conduct would result in harm to Palsgraf. He explained that negligence cannot be claimed unless there is breach of duty or a violation of rights—in this case, bodily security—in the absence of care. However, bodily security is not protected against unintentional interference. Judges Pound, Lehman, and Kellogg joined Cardozo in his opinion.
Concurring Opinions & Dissenting Opinions: Joined by Judges Crane and O’Brien, Judge Andrews dissented in writing that if an unreasonable act occurs, there is negligence regardless of damage. He stated defendants owe a duty to plaintiffs even if they are outside the area of hazard.
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