Palsgraf v. Long Island Railroad Co.
248 N.Y. 339 (1928)
proximate cause
duty
foreseeability
negligence
• Plaintiff: Mrs. Palsgraf, injured by falling scales after distant explosion
• Defendant's Act: Employees helped passenger board, causing package to fall
• Unexpected Element: Package contained fireworks
• Cardozo's Rule: Duty runs only to foreseeable plaintiffs
• Andrews' Dissent: Duty to world at large, limit by proximate cause
• Application: Palsgraf was outside foreseeable zone of danger
• Holding: No duty owed, defendant not liable
• Significance: Foundational case on duty analysis in negligence
• Defendant's Act: Employees helped passenger board, causing package to fall
• Unexpected Element: Package contained fireworks
• Cardozo's Rule: Duty runs only to foreseeable plaintiffs
• Andrews' Dissent: Duty to world at large, limit by proximate cause
• Application: Palsgraf was outside foreseeable zone of danger
• Holding: No duty owed, defendant not liable
• Significance: Foundational case on duty analysis in negligence