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Palsgraf v. Long Island R.R.
Court of Appeals of New York
162 N.E. 99 (N.Y. 1928)
Rule of Law
A defendant is only liable for negligence if he owes a legal duty to the plaintiff and breaches that duty, and if the resulting harm was reasonably foreseeable.
Palsgraf (plaintiff) was standing on a platform owned by the Long Island R.R. (railroad) (defendant). While she was waiting to catch a train, one train came by bound for another destination. It did not stop, but slowed down. At that moment, two men ran to catch the train as it was moving. One was carrying a package which, unbeknownst to anyone on the platform, contained fireworks. The first man jumped onboard the train safely, but the man with the package had difficulty. Two train employees helped pull and push him on. However, in doing so, the man dropped his package. It fell to the platform and exploded, causing several scales to dislodge and fly toward Palsgraf. The scales hit Palsgraf and she suffered injuries. She brought suit against the railroad for negligence. The trial court granted judgment for the plaintiff, and the appellate division affirmed. The railroad appealed.
Whether a defendant may be liable for harm caused to a plaintiff that is not reasonably foreseeable.
Holding and Reasoning (Cardozo, C.J.)
No. The railroad is not liable for Palsgraf’s injuries because Palsgraf’s injuries were not a reasonably foreseeable consequence of any possible negligence by the railroad. A defendant is only liable for negligence if he owes a legal duty to the plaintiff and breaches that duty, and if the resulting harm was reasonably foreseeable. Even if an act amounts to negligence, it is not actionable if it does not violate a legally protected interest of the plaintiff. The plaintiff may not sue on behalf of the risk of injury or bodily harm perpetrated against another. He can only recover for harm committed against his person or property. Here, the actions taken by the railroad’s employees involved the man running to board the train. Thus, if anyone could bring an action against the railroad for negligence, it would be him. Additionally, the only harm he could claim would be damage to his package, which was dropped in the course of his dealings with the railroad employees. However, this man is not bringing an action for property damage against the railroad. Rather, Palsgraf is bringing an action for bodily harm done to her. There is no possible link between the railroad employees’ conduct and her injuries. The package thrown by the employee did not appear to be dangerous, and thus his throwing it could not be seen as an unlawful act that would put Palsgraf in danger. Additionally, his act of pulling the man onto the train cannot be said to have caused Palsgraf bodily harm. Since no tortious act occurred against her, Palsgraf cannot bring an action for negligence against the railroad. The decision of the appellate court is reversed.