Palsgraf v. Long Island Railroad Co.
248 N.Y. 339 (1928)
proximate cause
duty
foreseeability
negligence
Palsgraf v. Long Island Railroad is the seminal case on duty in negligence law. When railroad employees helping a passenger caused him to drop fireworks that exploded and injured a distant bystander, Cardozo's majority held that duty runs only to foreseeable plaintiffs. Since Mrs. Palsgraf was outside the zone of danger, no duty was owed to her, regardless of the railroad's negligence toward others.