Palsgraf v. Long Island Railroad Co.: A Landmark in Tort Law

One of the most famous and foundational cases law students encounter in their study of tort law is Palsgraf v. Long Island Railroad Co., 248 N.Y. 339 (1928). Though decided nearly a century ago, the case remains a cornerstone for understanding the limits of negligence and the principle of foreseeability. It is not just a story about a freak accident on a train platform—it is a classic illustration of proximate cause and the boundaries of legal responsibility.

The Facts

The facts of Palsgraf are almost as famous as the opinion itself. Helen Palsgraf was standing on a train platform operated by the Long Island Railroad. Nearby, two railroad employees attempted to help a man onto a departing train. In the process, the man dropped a package—unknown to anyone at the time, it contained fireworks. The package exploded, causing a scale at the other end of the platform to fall and injure Mrs. Palsgraf.

She sued the railroad for negligence.

The Legal Issue: Proximate Cause and Foreseeability

The core legal issue in Palsgraf is whether the railroad's conduct was the proximate cause of Palsgraf’s injury. The majority opinion, written by Chief Judge Benjamin Cardozo, held that the railroad was not liable because the harm to Palsgraf was not foreseeable. According to Cardozo:

“The risk reasonably to be perceived defines the duty to be obeyed, and risk imports relation; it is risk to another or to others within the range of apprehension.”

In essence, the court said that because the employees could not reasonably foresee that helping a man onto a train would cause an explosion that would injure someone far away, there was no duty owed to Mrs. Palsgraf—and therefore no negligence.