The plaintiff Helen Palsgraf was standing at the platform station of Long Island Railroad Company after buying her ticket and waiting for her train. Suddenly, a man carrying a package rushed to catch another train that was moving away from the platform. He jumped into the train but he could not keep the balance and was about to fall when a railroad guard on the car reached forward to grab him and another man in the platform push him from behind to help him board the train.
During this process the man’s package which contained fireworks but guards were not aware of because it was wrapped in newspaper, fell in the railroad track and exploded. As a result of the explosion scales reached Hellen Palsgraf who was in at the other extreme of the platform causing physical injuries. The Hellen (plaintiff) sued the company (defendant) claiming it was liable for negligence. The jury in a trial verdict enters the judgment in favor of the plaintiff.
The defendant appealed claiming the plaintiff was not able to prove that the railroad company was negligent, but the appellate court affirmed the verdict. The defendant appealed further to the New York highest state court which reversed the judgment. Issues: 1. Does the actions of the railroad guard were an invasion of a legally protected interest or a protected right (a wrong) to the plaintiff? 2. Does the railroad guard violate a duty of care with the plaintiff standing in the railroad platform?
3. Does the law of proximate cause apply in these circumstances to determine that the defendant is liable for negligence? Decision: 1. No, the actions of the railroad guard are not considered an invasion to a legally protected interest or right of the plaintiff. Therefore, it is not negligence. 2. No, the railroad guard did not violate any duty of care with the plaintiff. Therefore, it was not negligence. 3. No, the law of proximate cause does not apply in this circumstance. Therefore, the defendant is not liable for negligence.
Reasons: 1. The action of conduct of the railroad guard is not considered a wrong or invasion of protected interest to the plaintiff because the wrong by the defendant was caused to the man who rushed to catch the train. What the plaintiff must show is a wrong to herself and not a wrong to someone else; therefore since the wrong is not caused to her, the company cannot be liable for negligence. In addition, the man was not injured or put into danger; instead the action of the railroad guard was to safe the man from falling.
Therefore, the only wrong caused was a violation to a property interest (the safety of his package). In brief the plaintiff was suing the company for the wrongs caused to the package owner since she did not suffer any wrong. Negligence is not actionable unless it involves the invasion of a legally protected interest, the violation of a right. Proof of negligence in the air will not do. 2. The railroad guard did not violate any duty of care to the defendant because the defendant was not aware neither of the existence of the package nor that is contained fireworks.
In addition, the package did not have any distinguishing characteristic to identify that it contained fireworks. Here, by concession, there was nothing in the situation to suggest to the most cautious mind that the parcel wrapped in newspaper would spread wreckage through the station. If the railroad guard would have been aware that the package contained fireworks when it fell down, and he would not have warned the plaintiff about, it would have been a violation of his duty of care. 3.
There was any sign or distinguishing characteristic in the package to determine that it contained fireworks. Thus, there was no way that the defendant could have known that the package contained explosives and consequently did not warn of plaintiff about the damage she was running when the package fell down. As a result the action of the defendant (not warning the plaintiff) was not only unwillingness but it was not liable for negligence. Therefore, since there was no negligence, proximate cause could not be determined.