Palsgraf v. Long Island Railroad
Citation: 248 N.Y. 339 (N.Y. 1928)
Facts
A railroad guard helped a passenger board a moving train, causing the passenger to drop a package of fireworks, which exploded. The explosion caused scales at the far end of the platform to fall, injuring Helen Palsgraf who was standing nearby. Palsgraf sued the railroad for the guard’s negligence.
Issue
Does a defendant owe a duty of care to a plaintiff who is outside the foreseeable zone of danger created by the defendant’s negligent conduct?
Holding
The Court of Appeals of New York (Cardozo, C.J.) held that the railroad owed no duty to Palsgraf because she was outside the foreseeable zone of danger. There can be no negligence without a duty, and duty runs only to foreseeable plaintiffs. Judge Andrews dissented, arguing that negligence toward anyone creates liability to all who are proximately harmed.
Rule
Cardozo majority: Duty is relational and runs only to those within the reasonably foreseeable zone of danger (foreseeability of plaintiff). Andrews dissent: Negligence is a breach of duty to the world at large; proximate cause, not duty, limits liability.
Significance
Palsgraf frames one of torts’ central debates — whether duty or proximate cause is the proper tool for limiting liability at the margins. The Cardozo approach (adopted by most U.S. courts) integrates foreseeability into the duty analysis; the Andrews approach treats proximate cause as a policy-based limitation. The case is essential for understanding how courts draw the line on liability for remote plaintiffs.