Palsgraf V. Long Island Railroad Case Summary

Case Study of Palsgraf v. Long Island Railroad Co.
Andrew William Pence
Liberty University

Abstract
Palsgraf was severely injured due to a blast that shook the railroad station. The unmarked package of fireworks that was dropped by another party boarding a moving train caused the explosion. The explosion caused large iron scales to fall on Plasgrof. As a result, Palsgraf sued the Long Island Railroad for the conductor’s negligence, whom she blames for pulling the commuter on the train. Which initiated the domino effect leading up to her injuries. Judge Cardoza ruled in favor of the Long Island Railroad because the conductor could not have known the passenger had fireworks. The action of the conductor was not a proximate-enough cause
Starting with legal factors, there are two major types of civil torts. One type deals with intent, while this particular case deals with negligence. Intent is also an element contained in criminal law and constitutional law. However, Palsgraf sued the conductor for negligence. “Negligence is when one party fails to act reasonably and harm occurs, even though that party did not intend to cause harm; the party is liable for any injuries or damages suffered by another party as a result of the unreasonable conduct.” (Melvin, p.272). There are five elements for negligence that must be proved in order to recover a lawsuit. In this case, the proximate (legal) cause was ruled in favor of the conductor. The relationship between the act and the injury must be forseeable, which it was not. Legally, the issue involved is negligence. This case also set the standard for foreseeability. The conductor and the commuter are socially involved. The special relationship involved is the train company to its passengers. Palsgraf was not a passenger at the time of the accident and the railroad carried their special relationship to the commuters. The conductor’s intent was to safely board the commuter. It was not the commuter’s intent to drop his package containing the explosives. The risk reasonably to be perceived defines the duty of helping the
“Negligence contains five elements; duty, breach of duty, cause in effect, proximate cause, and actual damages.” (McGrady). Though each element contains certain questions that must be answered about the conduct in question. For Duty, did the tortfeasor owe a duty of care to the injured party? The conductor or the commuters did not owe a direct duty of care to Palsgraf. Did the tortfeasor fail to exercise reasonable care? A breach of duty was not sustained. There was not a general duty to act. The conductor displayed reasonable care by helping the commuter onto the train. For cause and effect, would the injured party have suffered damages? Since, the conductor helped the commuter up causing the package to explode caused injuries to Palsgraf, there is a cause and effect. For the proximate cause, was there a legally recognized and close-in-proximity link between the breach of duty and the damages suffered by the injured party? The proximate cause doesn’t place Palsgraf in close proximity to the actions carried out by the conductor. For actual damages, did the injured party suffer some physical harm that resulted in identifiable losses? Finally, there were actual damages. Palsgraf suffered a severe injury according to the case study. To answer the original question, all of the other elements of a negligence tort was not satisfied in this case. The second and