Palsgraf v. Long Island Railroad Company

Legal action for negligence can only arise if the plaintiff's own right is violated, not if the plaintiff incurred injury due to a wrong against someone else.

This case arose from a bizarre accident. As Helen Palsgraf was waiting to buy a ticket to Rockaway, New Jersey on a platform operated by the Long Island Railroad Company, another train stopped at the station, and two men raced to catch it as it began to pull away. The first man reached the train without incident but the second, who was carrying what appeared to be a bundle of newspapers, stumbled as he boarded the train. A conductor on the train reached out to pull the passenger on board, while a second railway employee pushed the passenger from behind. During this awkward boarding the passenger dropped his parcel, which in fact contained fireworks. The package exploded upon hitting the rails and the shock created by the explosion caused a heavy scale to topple over and injure Ms. Palsgraf.

Ms. Palsgraf successfully sued the Long Island Railroad Company for compensation for her injuries in the Kings County, New York State Circuit Court. The Long Island Railroad Company appealed this decision to the Appellate Division of the State Supreme Court, Second Department, which upheld the lower court's ruling. The company appealed once more to the New York Court of Appeals, which agreed to hear the case.

Attorneys for the Long Island Railroad Company argued that no negligence had been proven, and that Ms. Palsgraf's claim should have been dismissed by the lower courts. Palsgraf's lawyers countered that negligence had been proven and the earlier decisions justified.

On 29 May 1928 the New York Court of Appeals found in favor of the Long Island Railroad Company by a margin of 4-3, ruling that "the basis of an action for negligence must be a violation of the plaintiff's own right, and not merely a wrong against someone else." Therefore, although the company's employees were negligent in making the passenger drop his parcel, their negligence affected only him, and not Ms. Palsgraf, who was standing at least 20 to 30 feet away from the spot where the package fell. An ambiguity in the decision makes this case particularly interesting while also reducing its legal impact. The wording of the decision strongly implies that had the railroad employees known that the parcel contained explosives, they would have been negligent with regard to Ms. Palsgraf's safety, and the railroad would have been liable to compensate her for her injuries. Thus, liability is not involved in a case where an injury results from consequences of negligence that could not have been reasonably foreseen. The decision also implied that had the man carrying the explosive parcel been the one injured, he would have been entitled to compensation for his injuries. Dissenting Justices Andrews, Crane, and O'Brien were particularly troubled by the latitude for interpretation in individual cases allowed for by this decision.

Ms. Palsgraf entered a final petition for a rehearing of the case, claiming that she might have been standing closer to the explosion than she had previously indicated, but her motion was denied on 9 October 1928. This case served to clarify the legal definition of actionable negligence by stating that such negligence must be directed against the plaintiff personally.