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Palsgraf v. Long Island Railroad Co.

New York Court of Appeals
248 N.Y. 339, 162 N.E. 99 (1928)

Written by Abby Roughton, JD

Facts

Helen Palsgraf (plaintiff) was standing on a railway platform owned by the Long Island Railroad Co. (railroad) (defendant). While Palsgraf was waiting to catch a train, a train bound for another destination stopped at the station. Two men ran to catch the train as it pulled away. One man was carrying a small, newspaper-covered package that, unbeknownst to anyone on the platform, contained fireworks. The first man jumped aboard the train safely, but the man carrying the package had difficulty. Two railroad employees helped him board the train, one pulling him onto the train and another pushing him from behind. In the process, the man dropped the package. It fell to the rails and exploded, causing scales at the other end of the platform to dislodge and fall, injuring Palsgraf. Palsgraf sued the railroad for negligence, arguing that the railroad employees were negligent when helping the man board the train and that their negligence caused Palsgraf’s injury. The trial court granted judgment for Palsgraf, and the appellate division affirmed. The railroad appealed to the New York Court of Appeals.

Rule of Law

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Holding and Reasoning (Cardozo, C.J.)

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Dissent (Andrews, J.)

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