Palsgraf v. Long Island Railroad Co. [1928]
248 N.Y. 339 (1928) · New York Court of Appeals · New York, United States
Summary
Canonical duty and proximate cause case.
Facts
Railroad employees helped a passenger board, dislodging a package of fireworks that injured Helen Palsgraf far away.
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
Duty is relational and owed to foreseeable plaintiffs within the zone of danger.
Significance
Canonical duty and proximate cause case.
Related Cases
No related cases listed.
Exam Tips
Review the ratio and reasoning before applying this case in problem questions.