Palsgraf v. Long Island Railroad Co.
248 N.Y. 339, 162 N.E. 99 (1928) · New York Court of Appeals
- Case name & citation
- Palsgraf v. Long Island Railroad Co., 248 N.Y. 339, 162 N.E. 99 (1928).
- Facts
- Railroad guards helped a man board a moving train, dislodging a package of fireworks he carried. The package exploded; the shock allegedly toppled scales at the far end of the platform, injuring Helen Palsgraf, a waiting passenger. She sued the railroad for the guards’ negligence.
- Issue
- Does a defendant owe a duty of care to a plaintiff whose injury was not a reasonably foreseeable result of the defendant’s conduct?
- Rule
- Negligence is a relational concept: a duty of care is owed only to those within the reasonably foreseeable zone of danger created by the defendant’s conduct. There is no liability for an unforeseeable plaintiff.
- Reasoning / Analysis
- Cardozo, J., framed duty in terms of foreseeability and the relationship between the parties. The risk reasonably to be perceived defines the duty owed; conduct is negligent only toward those whose injury could be foreseen. Because nothing suggested the package was dangerous, no hazard to a distant bystander was apparent, so no duty ran to Palsgraf and no negligence claim could lie.
- Holding
- No. The railroad owed Palsgraf no duty because her injury was not a reasonably foreseeable consequence of helping the passenger board; the guards’ conduct was not a wrong "in relation to her."