Torts I, Pages 329–335

Palsgraf v. Long Island R.R. Co.

Court of Appeals of New York, 1928

Judgment:

Reversed.

Facts:

Two men ran toward defendant's train while it was leaving. They both boarded, but one seemed unsteady. Two guards held the door open and helped him stay on, but the man dropped his package. Unbeknownst to the guards, the package contained fireworks, which fell and exploded. Plaintiff was standing on defendant's railroad platform and was injured by a scale that fell over and hit her because of the explosion.

Procedural History:

Trial court found for the plaintiff.

Issue:

Is one the proximate cause of injury when he committed the action unknowingly?

Reasoning:

Defendant did not know the package was explosive. Therefore, plaintiff was not a reasonably foreseeable victim, and defendant did not have a duty to her, making proximate cause irrelevant.

Rule/Holding:

The defendant must have breached a duty before considering proximate cause.

Dissenting Opinion:

Plaintiff should be liable for all injuries resulting from the direct result of his actions, even if not reasonably foreseeable.

Takeaway:

Defendants are not liable for harm to unforeseeable victims.