Palsgraf v. Long Island Railroad Co.

When performing their operations, firms need to exercise extreme caution to avoid causing harm. For example, they should take steps to rid their premises of hazards that could result in injury. Should they fail to prioritize safety, companies expose themselves to the risk of legal liability. Tort law holds firms liable for foreseeable injuries that they fail to prevent. The case of Palsgraf v. Long Island Railroad Co. underscores the importance of ensuring safety.

Summary of Facts 

It has been suggested above that the Palsgraf v. Long Island Railroad Co. case is concerned with tort and liability. In this case, Palsgraf sought to be awarded damages for the injuries that she sustained following an incident at a railway platform operated by the Long Island Railroad Co. While waiting to board her train, Palsgraf was hit by a scale that left her with injuries and caused her to develop a stammer. This incident was triggered by a male passenger who dropped a package that contained fireworks. As the man attempted to get onto his train which was departing the station, he dropped the package and it exploded. In her case, Palsgraf argued that the help that the man received from the employees of Long Island Railroad Co. contributed to the incident and led to her injuries. Fearing that the man would miss the train, two employees helped him board. Before making its way to the New York Supreme Court, the case had been heard by lower courts which found in favor of Palsgraf and awarded her damages. Dissatisfied with the judgments issued by the lower courts, the Long Island Railroad Co. launched an appeal. The main argument that the company raised in the appeal was that it was not liable for the injuries that Palsgraf sustained.

Issue 

When hearing cases, courts are usually mandated with providing answers to the issues in contention. The New York Supreme Court was required to render a judgment on the issue of how remote damage should be for an individual to bring a suit regarding liability (“Helen Palsgraf, Respondent”, n.d). As already stated above, Palsgraf contended that by supporting the man who was about to miss his train, the railroad employees set the stage for the explosion to occur, thereby leading to her injuries. The court was charged with determining if the link between the actions of the employees and the injuries that Palsgraf sustained is of the causative variety (“Helen Palsgraf, Respondent”, n.d). Analysts who have examined this case have expanded the issue to include the basic elements that must be fulfilled for liability to be established. Today, the ruling that the Supreme Court issued is regarded as standard in determining cases involving tort and liability. As will be made clear in the following section, the court stipulated the conditions that must be met for liability to be considered.

Summary of Rule 

In its ruling, the New York Supreme Court disagreed with the lower courts which had found the Long Island Railroad Co. to be liable for the injuries that Palsgraf suffered. As noted above, the court’s ruling set the standard for tort law. The court found that the railroad company was not liable (“Helen Palsgraf, Respondent”, n.d). However, it did rule that the two employees had acted negligently. Traditionally, a finding of negligence would lead a court to rule that there is liability. This was not true in this case. The court found that the negligence was not directed at Palsgraf, and as such her claim that the company was liable lacked merit and was dismissed. Another rule that the court established concerns the requirement that a violation of an individual’s rights must have occurred for liability to be established. Given the remote association between the conduct of the railroad employees and Palsgraf’s injuries, the court determined that her rights were not violated, further supporting the judgment that the railroad company could not be held liable (“Helen Palsgraf, Respondent”, n.d). Whether the defendant could foresee the damage that resulted is another question that the court’s ruling addressed. In the section on the facts of the case, it has been noted that the explosion occurred when a passenger’s package dropped. The court needed to determine if the railroad company could have foreseen this series of events (“Helen Palsgraf, Respondent”, n.d). Its ruling indicates that it was impossible for the railroad employees to predict that by helping the passenger, the package would fall, explode and cause the scale to hit Palsgraf, leading to her injuries. In essence, the court determined that the circumstances surrounding the case were so flimsy that they could not sustain a judgment of liability. Had it affirmed the judgments of the lower courts, the Supreme Court would essentially sanction the filing of lawsuits in any other set of circumstances where individuals suffer harm even when the link between an incident and the harm is remote and there is barely any causative association.

Alternative Facts 

A fresh set of facts can be constructed that would lead the court to rule in favor of Palsgraf and find the railroad company to be negligent and therefore liable. Suppose that the facts of the case remain as described earlier. However, these facts should accommodate a small change involving a clear label on the package. The label reads “DANGER. HANDLE WITH CARE” and has the explosive symbol. The two employees see this label and continue to help the man who is precariously and dangerously holding on the package as he attempts to get onto the moving train. Palsgraf is only ten feet away from the train. These changes to the facts would force the court to find the railroad company to be liable. This is because the facts fulfill the basic conditions for liability. For example, the label on the package indicates that the employees should be able to predict that the package could drop and explode, causing injury to Palsgraf who is standing a few feet away. If they help the man board, the employees will be acting negligently and the company will have violated its duty of care to Palsgraf and any other passengers who sustain injury.

Another set of facts can be constructed to help the court rule in favor of the railroad company. Consider a case where the facts remain as they are in the Palsgraf v. Long Island Railroad Co. However, as opposed to the situation in this case where Palsgraf suffers injury, no one is hurt. Despite having suffered no injury, Palsgraf still sues the company, arguing that the incident caused her distress. It is highly likely that the court will dismiss this case. For liability to be proven, a number of conditions must be met. These conditions include duty of care, breach of this duty, injury or loss and causation (Lunney & Oliphant, 2008). Palsgraf will be hard pressed to persuade the court that the railroad company breached its duty to insulate her against injury or loss. However, her most daunting challenge will be to prove that she suffered harm. Since no injuries were reported, the court has no choice but to dismiss the case.

In conclusion, there is no doubt that tort law is intended to prevent harm and to challenge companies to adopt measures that ensure safety. The case involving the Long Island Railroad Co. and Palsgraf demonstrated how tort law works to balance the interests of companies and individuals who argue that they have suffered harm as a result of negligent conduct. This case is critical because it established the rules and standards that are employed today in tort law. It is important for courts to use the standards that the case set when examining cases concerning liability.

References

Helen Palsgraf, Respondent, v The Long Island Railroad Company, Appellant.(n.d). Retrieved April 10, 2019 from http://www.courts.state.ny.us/reporter/archives/palsgraf_lirr.htm

.Lunney, M., & Oliphant, K. (2008). Tort law: text and materials. Oxford: Oxford UP.