Palsgraf v. Long Island Railroad Co., 284 N.Y. 339, 162 N.E. 99 (1928)
FACTS: A man carried a package that contained fireworks onto a train. When he dropped the package, it fell onto the rails. The fireworks inside the package exploded. As a result of the explosion, the Plaintiff was injured.
ISSUE: Whether Plaintiff can recover damages from the Defendant for negligence as a result of the explosion.
RULE: Negligence requires a showing that defendant owed a duty of care to plaintiff, defendant breached duty of care, plaintiff was injured, and defendant’s negligence resulted in plaintiff’s injuries. Under the doctrine of reasonable foreseeability, the defendant is only liable for harm which he reasonably foresaw.
ANALYSIS: In the Court’s evaluation of the case, the Plaintiff cannot bring an action for negligence unless she can show the invasion of a legally protected interest. In other words, a violation of a right. Here, the Court felt the Plaintiff failed to show how the explosion was wrong to herself, in violation of her own right. The Court further said, if the Plaintiff fails to bring a tort for the court to redress, it cannot consider damages.
CONCLUSION: I disagree with the Court, in that, Plaintiff failed to show the Defendant was the cause of the explosion that led to her injuries, and that she cannot recover damages.
DISSENT: (Andrew, J., dissenting) I agree with Justice Andrew, in that, Defendant’s wrongful act made them liable for its proximate results. See In re Polemis. In his view, when a plaintiff’s injuries result from defendant’s unlawful act, the defendant is liable for the consequences. Justice Andrew further said that the unexpected, unforeseen and unforeseeable does not matter.