Can a railroad company be held liable for injuries to a passenger caused by the explosion of a package carried by another passenger, when the railroad's employees had no knowledge of the package's dangerous contents?

Mrs. Palsgraf was standing on a railroad platform after purchasing a ticket when a train arrived at the station. Two men rushed to board the train, with one man carrying a package. As railroad guards attempted to assist the man with the package onto the train, they dislodged the parcel, causing it to fall onto the tracks. The package, approximately fifteen inches long and wrapped in newspaper, contained fireworks but showed no external indication of its contents. Upon impact, the package exploded. The explosion caused scales at the opposite end of the platform to fall, striking and injuring Mrs. Palsgraf. As a result of her injuries, Mrs. Palsgraf filed a lawsuit against the railroad company.

The plaintiff initially brought suit against the railroad company in a lower court. The lower court ruled in favor of the plaintiff and awarded damages. Dissatisfied with this outcome, the railroad company appealed the decision. As a result of this appeal, the case was elevated to the New York Court of Appeals for further review and adjudication.

(Cardozo, J.)

No. A railroad company cannot be held liable for injuries to a passenger caused by the explosion of a package carried by another passenger when the railroad's employees had no knowledge of the package's dangerous contents. Negligence is not actionable unless it involves the invasion of a legally protected interest. The conduct of the defendant's employees, while possibly negligent towards the package carrier, was not negligent in relation to the plaintiff standing at a distance. No duty of care was owed to the plaintiff in this specific situation because the harm was not reasonably foreseeable. Foreseeability is a key factor in determining the scope of duty in negligence cases. The defendant's actions must create a foreseeable risk of injury to a foreseeable plaintiff. Here, the risk of harm to someone standing far from the incident was not within the range of apprehension. The orbit of danger as disclosed to the eye of reasonable vigilance would be the orbit of duty. One who jostles one's neighbor in a crowd does not invade the rights of others standing at the outer fringe when the unintended contact casts a bomb upon the ground. The wrongdoing of the guards, if any, was not a wrong in its relation to the plaintiff, standing far away. Proximate cause, in this instance, is contingent upon a showing of foreseeable harm to a foreseeable plaintiff. The connection between the defendant's negligence and the plaintiff's injury is too attenuated to establish liability. To hold otherwise would extend liability in an indeterminate manner, far beyond the bounds of reasonable foresight. The law draws a line between liability and non-liability somewhere between these extremes, and this line must be drawn based on practical considerations of policy and a sense of justice.

Dissent (Andrews, J.) Everyone owes a duty to the world at large to refrain from acts that may unreasonably threaten the safety of others. Once negligence is established, the defendant should be liable for all consequences proximately caused by the negligent act, even if the specific harm was not foreseeable. This broader view of duty and proximate cause better serves the interests of justice and public safety.

Concurrence (Pound, J.) Concurred with the majority opinion without providing a separate written opinion.

Concurrence (Lehman, J.) Concurred with the majority opinion without providing a separate written opinion.

Concurrence (Kellogg, J.) Concurred with the majority opinion without providing a separate written opinion.

Dissent (Crane, J.) Dissented with the majority opinion without providing a separate written opinion.

Dissent (O'Brien, J.) Dissented with the majority opinion without providing a separate written opinion.