Palsgraf v. Long Island Analysis and Case Brief
By: Jeffrey Boswell, Steven Casillas, Antwan Deligar & Randy Durham
Professor Eden Allyn
26 May 13
The plaintiff, Helen Palsgraf, filed a suit against the Long Island Rail Road Company. The plaintiff claimed the Long Island Railroad Company’s negligence resulted in injury to her person. A passenger was attempting to board a moving train and lost his footing. The man looked as though he was going to fall. A guard reached out to help the man onto the train and another guard attempted to push him onto the train from behind. The man was carrying a box that was covered by ...view middle of the document...
How did the court come to these conclusions? For that answer we must look at the facts. The original ruling, in the plaintiff’s favor, was based on the law. One has to take into consideration the fact that although the servant did not know the contents of the package, there should be some form of liability to the defendant. Acknowledging that the plaintiff stood many feet away from the commotion, it is obvious that her injuries were caused by the actions of the guard.
Looking at the case of Smith v. London and South Western Railway, where a train caused a fire that damaged a building 200 yards away, the courts decided that the defendant be held liable even though the extent of damage could not be foreseen (Smith V. London & South Western Railway Co., 1870).
The appeals court did conclude in favor of the defendant citing the actions of the defendant’s servant did cause legally recognizable injury to the plaintiff, but could not be proven as a breach duty since the package was not marked. Using the reasonable person standard, one could conclude that there was no way the defendant’s servant could have known the contents of the package. The risks from servant’s actions were unreasonable and the dangers that ensued were not foreseeable.
In explaining its decision, the court cited a case tried by the Supreme Court, Parrot v. Wells-Fargo & Co. In that case the defendant, Wells-Fargo & Co., was a tenant in the lower part of a building owned by the plaintiff. A package, having no outward markings indicating its contents, was put in the care of Wells-Fargo; the package contained nitro-glycerin, an...