Palsgraf v. Long Island R.R. Co.
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Case Citation:
Palsgraf v. Long Is. R.R. Co., 248 N.Y. 339 (1928).
Procedural History:
Palsgraf (P) sued the Railroad (RR) for negligence. The trial court ruled in Palsgraf's favor. The appellate court affirmed. The RR appealed again.
Issue:
Was the fireworks explosion a tort, and if so, can the Defendant be held liable for negligence when a Plaintiff is injured by unforeseeable events?
Facts:
While Palsgraf was standing on a railroad platform, two men ran to catch a departing train. Railroad employees helped one man board. In the process, he dropped a package he was holding that contained fireworks. It exploded, and the shock caused scales at the far end of the platform to fall and strike Palsgraf, injuring her.
Rule:
B. Negligence is not actionable unless it involves a legally protected interest: the violation of a right.
Reasoning:
A duty exists only for reasonably foreseeable risks. An injury alone is not enough to establish a valid legal claim. When harm is not intentional, the conduct must have posed a danger so apparent that it creates a duty of care. Without a legal wrong, there can't be any damages.
Holding:
The Railroad is not liable for Palsgraf's injuries because the employees' conduct did not create a foreseeable risk of harm to her.
Order:
Reversed, complaint dismissed.
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