Palsgraf v. Long Island Railroad Co.Court of Appeals of New York, 1928. 248 N.Y. 339, 162 N.E. 99.
Facts: Whilst the defendant’s employees were helping a passenger aboard a train, the package he was carrying was dislodged and fell on the track. The package, which gave no indication of its contents, contained fireworks which exploded when they hit the track. The vibrations from the explosion caused scales some distance away to fall upon and injure the plaintiff Helen Palsgraf, an intending passenger. Palsgraf sued the railroad, claiming negligence. The Trial Term and the Intermediate Appeals Court found in favor of Palsgraf. The Long Island Railroad Co. appealed.
Issue: Did the defendant (Long Island Railroad Co.) act negligently toward the plaintiff (Helen Palsgraf) by actions that caused another passenger’s unmarked package of of fireworks to explode, knocking scales over on the plaintiff.
Decision: No. Negligence is constituted by a breach of duty to the individual complaining the neglect of which invades a legally protected interest. The Court of Appeals of New York reversed the decision of the lower courts and dismissed the complaint, with costs in all courts
Reason: Before an action may be considered negligent, a failed duty to the individual complaining must be found, which would have averted or avoided the injury. Nothing about the situation reasonably suggested that the fall of the package would result in an explosion which would harm those at a distance. As such, there was nothing which could foreseeably be done to prevent the accident. Thus, the defendant did not act toward the plaintiff negligently. Any negligence was to the passenger the contents of whose package were destroyed.
“Negligence is not actionable unless it involves the invasion of a legally protected interest, the violation of a right.” Negligence towards another passenger does not constitute negligence toward the plaintiff, though injury may result. For an act to be considered negligent, a violation of the complaining individual’s right must have occurred. One cannot complain of negligence to another party.
The Dissenting opinion argued that because negligence toward another passenger caused the injury to the plaintiff, the railroad should be liable. Often injury does not result from infringement of rights. A negligent act affects the world at large. Thus, an act may be negligent to the world at large, and the defendant is liable to anyone injured by the act, however unexpected the injury.