Palsgraf v. Long Island Railroad Co.

E100412

Palsgraf v. Long Island Railroad Co. is a landmark 1928 New York Court of Appeals case, authored by Judge Benjamin Cardozo, that established the modern American doctrine of proximate cause and foreseeability in negligence law.

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Generate an image of a palsgraf v. Long Island Railroad Co. (Palsgraf v. Long Island Railroad Co. is a landmark 1928 New York Court of Appeals case, authored by Judge Benjamin Cardozo, that established the modern American doctrine of proximate cause and foreseeability in negligence law.)

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Statements (48)

Predicate Object
instanceOf court case ⓘ
landmark case ⓘ
negligence case ⓘ
tort law case ⓘ
areaOfLaw negligence ⓘ
tort law ⓘ
chiefJudgeAtTime Benjamin N. Cardozo ⓘ
citation 162 N.E. 99 ⓘ
248 N.Y. 339 ⓘ
country United States ⓘ
court New York Court of Appeals ⓘ
decisionDate 1928-05-29 ⓘ
decisionYear 1928 ⓘ
defendant Long Island Railroad Company ⓘ
dissentingOpinionBy William S. Andrews ⓘ
dissentingView Liability should be based on whether the defendant’s act was a substantial factor in producing the injury, not on foreseeability of the particular plaintiff ⓘ
factSummary Railroad guards helped a passenger board a moving train, causing a package of fireworks to fall, explode, and knock down scales that injured the plaintiff ⓘ
frequentlyCitedIn U.S. tort law casebooks ⓘ
fullName Palsgraf v. Long Island Railroad Co. ⓘ
holding The railroad owed no duty of care to the plaintiff with respect to the unforeseeable explosion and resulting injuries ⓘ
influenced American negligence law ⓘ
Restatement (Second) of Torts approach to duty and proximate cause ⓘ
issue Whether the defendant railroad owed a duty of care to the plaintiff for injuries resulting from an unforeseeable chain of events ⓘ
judgeAuthoringMajorityOpinion Benjamin N. Cardozo ⓘ
jurisdiction New York ⓘ
keyConcept foreseeable plaintiff ⓘ
proximate cause as limitation on liability ⓘ
relational duty of care ⓘ
zone of danger ⓘ
languageOfDecision English ⓘ
legalDoctrine foreseeability ⓘ
proximate cause ⓘ
legalPrincipleEstablished duty of care is owed only to those in the reasonably foreseeable zone of danger ⓘ
legalSignificance Clarified distinction between duty and proximate cause in negligence analysis ⓘ
Established foreseeability as a central test for duty in negligence ⓘ
locationOfIncident Long Island Railroad station in New York ⓘ
majorityHolding Negligence is not actionable unless it involves the invasion of a legally protected interest of the plaintiff within the range of apprehension ⓘ
majorityOpinionBy Benjamin N. Cardozo ⓘ
partyTypeDefendant railroad company ⓘ
partyTypePlaintiff individual ⓘ
plaintiff Helen Palsgraf ⓘ
proceduralPosture Appeal from a judgment in favor of the plaintiff ⓘ
remedy Complaint dismissed ⓘ
resultOnAppeal Judgment for the plaintiff was reversed ⓘ
shortName Palsgraf ⓘ
stateCourt New York ⓘ
taughtIn first-year law school torts courses in the United States ⓘ
timePeriodOfIncident early 1920s ⓘ

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Referenced by (7)

Full triples — surface form annotated when it differs from this entity's canonical label.

Benjamin N. Cardozo → notableWork → Palsgraf v. Long Island Railroad Co. ⓘ
subject linked to: Justice Benjamin N. Cardozo
Palsgraf v. Long Island Railroad Co. → fullName → Palsgraf v. Long Island Railroad Co. ⓘ
Palsgraf v. Long Island Railroad Co. → shortName → Palsgraf ⓘ
linked to: Palsgraf v. Long Island Railroad Co.
Helen Palsgraf → injuredIn → Palsgraf v. Long Island Railroad Co. ⓘ
Helen Palsgraf → caseCitation → Palsgraf v. Long Island R.R. Co., 248 N.Y. 339 (1928) ⓘ
linked to: Palsgraf v. Long Island Railroad Co.
Long Island Railroad station in New York → associatedCourtCase → Palsgraf v. Long Island Railroad Co. ⓘ
William S. Andrews → notableWork → dissent in Palsgraf v. Long Island Railroad Co. ⓘ
linked to: Palsgraf v. Long Island Railroad Co.