Palsgraf Case Brief
1. Who is Helen Palsgraf?
Helen Palsgraf is the plaintiff, an intending passenger who was standing on a Long Island Railroad train platform after buying a ticket. She was injured when another passenger was pushed by the railroad employee, dropping a package containing fireworks, which then exploded. She filed a case in court against the Long Island Railroad for negligence.
2. What are the facts of the case?
Defendant railroad appealed a judgment of the Appellate Division of the Supreme Court in the Second Judicial Department (New York), which affirmed the trial court’s holding that the railroad was responsible for injuries to plaintiff passenger resulting from an explosion. The passenger was standing on a platform of the railroad after buying a ticket. A train stopped at the station, and a man ran forward to catch it. When he attempted to board the train in haste, he dropped a package containing fireworks. As a result, the passenger was injured from the subsequent explosion and sought to hold the railroad liable for negligence. Pursuant to a jury ruling, the trial court entered a judgment in favor of the passenger. The appellate court declared, and the railroad appealed.
Upon final determination, the court reversed the judgment, holding that the passenger failed to prove that the railroad’s alleged negligence proximately caused her injuries. Essentially, the court held that under the foresee ability test, it was not reasonable to hold that the railroad’s alleged negligence was the cause of the passenger’s injuries. Rather, the explosion was the proximate cause, and the railroad could not have reasonably expected such a disaster. The outcome indicated the court revoked the judgment of the appellate court and then dismissed the complaint.
3. Why is she suing the Railroad instead of the actual individual who had the dynamite?
She is suing the Railroad instead of the actual individual who had the dynamite because she claimed that her injury resulted from negligence acts of one of their employee. She claims that the employee is the one who pushed the individual from behind, making the package to be dislodged from the individual, leading to its fall and eventual explosion.
4. What facts does the Judge discuss that really isn’t that important to the holding of the case?
The holding of the case was that the defendant could not be held liable for an injury that could not be reasonably foreseen. The facts that the judge discusses that are not important to the holding of the case are that the employee could not have known that the contents of the package wrapped in the newspaper were dangerous and that its falling would result in an explosion.
5. Is there always someone at fault when an individual is injured at no fault of their own?
It is not always another person’s fault when an individual is injured at no fault of his or her own. For example, it is not the employee’s fault that Palsgraf was injured by the explosion caused by the package falling. The employee had no idea of the contents of the package and so he did not know that it could injure Palsgraf.
6. Imagine the repercussions this precedent could have created for businesses had it decided it differently. What if you owned the railroad, or were an employee of it?
The repercussions this precedent could have created for businesses had it decided differently could have been damaging. Businesses could have always been held responsible for the actions of their employees. The decision could have tarnished the reputation of railroad and all their employees. The public would have a negative opinion about the organization and all its employees. As a result, they would have lost many potential customers and the business would have made less or no profits at all.
7. Discuss the importance of foresee ability and proximate cause in the law.
The concept of foresee ability in the law tends to limit liability to the consequences of an act that could reasonably be foreseen rather than every single consequence that follows. Proximate cause refers to the immediate cause of an injury or accident. The importance of foresee ability is that incase an accident was not foreseen then the defendant cannot be found guilty. For example, in this case, the proximate cause, which is the explosion, is responsible for Palsgraf injury and not the employee, since the employee did not have the ability to foresee an explosion that would cause an injury.
8. Do you think the outcome is fair?
The outcome of the case is fair. The outcome was the court reversed the judgment of the appellate court and dismissed the complaint. This was because the court held that under the foresee ability test, it was not reasonable to hold that the railroad’s alleged negligence was the cause of the passenger’s injuries. Rather, the explosion was the proximate cause, and the railroad could not have reasonably expected such a disaster.
9. What did the dissent believe? Do you agree?
The dissent believes that everyone has the duty of refraining from acts that may unreasonably threaten the safety of others. In determining proximate cause, the court must ask whether there was a natural and continuous sequence between the cause and effect and not whether the act would reasonably be expected to injure another. The court must consider that the greater the distance between the cause and the effect in time and space, the greater the likelihood that other causes intervene to affect the result. In this case, there was no remoteness in time and little in space. Injury in some form was probable.
I therefore do not agree with the dissent because the railroad could not have predicted such an outcome from the falling of the package.