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Palsgraf v. Long Island Railroad Co.

(1928)

New York Court of Appeals - 248 N.Y. 339

tl;dr:

When Defendant's employees helped a man board a train, the man's package fell, causing a fireworks explosion and injuring Plaintiff 20ft away; Court holds Defendant owed no duty to Plaintiff.

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ICRAIssue, Conclusion, Rule, Analysis for Palsgraf v. Long Island Railroad Co.

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Facts & HoldingPalsgraf v. Long Island Railroad Co. case brief facts & holding

Facts:Plaintiff was standing on a platform of Defendant's railroad. About...

Holding:The NY Court of Appeals reversed.Judge Cardozo framed this as...

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Palsgraf v. Long Island Railroad Co. | Case Brief DeepDive
Majority opinion, author: Cardozo, Ch. J.
Level 1
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The plaintiff was injured by falling scales after a package of fireworks exploded on a railroad platform owned by the defendant. The plaintiff is suing for damages, but the defendant argues that their guard's conduct was not negligent towards the plaintiff because there was no apparent hazard. Negligence requires a duty to the individual complaining, and the plaintiff's right cannot be based on a wrong to someone else's interest. The wrongdoer is the person who carries the bomb, not the one who explodes it without suspicion of danger. The lower court's decision is not mentioned.

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Dissenting opinion, author: Andrews, J.
Level 1
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The liability of a defendant's servant for damages caused by an explosion is discussed in the text, even if they had no knowledge of the contents. According to the dissenting opinion, negligence includes unreasonable acts that impact the world at large. To determine the extent of causation, the court should consider all relevant factors, such as whether the event would not have happened without the action, whether there was a natural and continuous sequence between cause and effect, and whether the cause was a significant factor in producing the effect. The foreseeability of injury must also be considered, and the court should evaluate whether the negligent party could have reasonably foreseen the injury. In the case mentioned, the defendant's act was negligent, and they are liable for its proximate consequences. The weighing machine falling on the plaintiff was not a remote cause.

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