Helen Palsgraf V The Long Island Railroad Case Brief Summary

Helen Palsgraf, Respondent, v. The Long Island Railroad Company, Appellant

Facts

A passenger carrying a package, while hurrying to catch and board a moving Long Island Rail Road train, appeared to two of the railroad's (Defendant's) employees to be falling. The employees were guards, one of whom was located on the car, the other of whom was located on the platform. The guard on the car attempted to pull the passenger into the car and the guard on the platform attempted to push him into the car from behind. The guards' efforts to aid the passenger caused the package the passenger was holding to fall on the rails. Unbeknownst to the guards, the package, which was approximately 15 inches (38 cm) long and wrapped in newspaper, contained fireworks, and the package exploded when it hit the rails. The shock reportedly knocked down scales at the other end of the platform (although later accounts suggest that a panicking bystander may have upset the scale), which injured Mrs. Helen Palsgraf (Plaintiff). Palsgraf sued the railroad, claiming her injury resulted from negligent acts of the employee. The trial court and the
The court wrote that "there was nothing in the situation to suggest to the most cautious mind that the parcel wrapped in newspaper would spread wreckage through the station. If the guard had thrown it down knowingly and willfully, he would not have threatened the plaintiff's safety, so far as appearances could warn him." Without any perception that one's actions could harm someone, there could be no duty towards that person, and therefore no negligence for which to impose liability (duty is a matter of law to be decided by a judge; therefore, a finding that there was no duty was sufficient to overturn the jury's guilty