Palsgraf v. Long Island Railroad

What Happened: Mrs. Palsgraf was standing on a railroad platform after she bought a ticket
from Long Island Rail Road. Two men ran to catch a train that was pulling out from the
platform. The first man jumped aboard easily but the second man, who was carrying a package,
failed to jump aboard the railroad car the first time. A train employee, who had held the door
open for the second man reached forward to help him in, and a guard on the platform pushed him
from behind at the same time. In this act, the package the man was carrying was dislodged and
fell upon the rails. The package contained fireworks, but there was nothing from its appearance
to give Long Island Rail Road notice of its contents. The fireworks exploded when they fell and
the shock of the explosion caused some scales at the other end of the platform to fall.
Unfortunately, the scales struck Mrs. Palsgraf, causing her to be injured. Ms. Palsgraf initiated a
lawsuit against Long Island Rail Road company to receive compensation for her injuries. Ms.
Palsgraf was awarded damages in the trial court and the Defendant appealed.

Question Before the Court: Does a Defendant owe a duty of care to Plaintiff who is outside the
reasonably foreseeable zone of danger?

Court Ruling: The majority held that negligence is based on the foreseeability of the harm
between the parties and overturned Ms. Palsgraf’s victory in the lower court.

Dan Garner

Author Dan Garner

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