Palsgraf v Long Island Railroad

162 NE 2d 99 (NY 1928)

Summary

Two train guards helped a passenger board a train when they carelessly knocked an innocent-looking parcel out of his hands, unknown to them the package contained fireworks. The parcel fell under the train, causing an explosion which led to a set of scales at the other end of the platform falling onto the claimant and injuring her. The claimant's action failed in the Supreme Court of New York because injury to the claimant had not been a foreseeable consequence of the guard's conduct.

Facts

The claimant was standing on a station platform purchasing a ticket. Meanwhile, two men ran to catch a train that had stopped at the station and one of the men tripped. Two railway staff members tried to help the fallen man, and carelessly knocked an innocent-looking parcel out of his hands. Unknown to the staff, the package contained fireworks. The package fell under the train and exploded. The explosion caused a set of scales to fall at the other end of the platform, which injured the claimant. At first instance, the court found in favour of the claimant, and the judgment was affirmed on appeal. The defendant appealed to the Supreme Court of New York.

Issue

In an English law context, the issue is remoteness of damage and duty in fact for negligence claims.

Held

The court sided with the Long Island Rail Road and held that Mrs Palsgraf's claim failed because injury to the claimant had not been a foreseeable consequence of the guard's conduct. The court acknowledged that while the guards who caused the fireworks package to fall were careless; they were not negligent towards the claimant. Maybe the guards had acted negligently towards the first passenger and his property. Still, an injury to the claimant had not been one of the risks that made their conduct negligent.