Palsgraf v. Long Island R.R. IRAC Brief Assignment PDF

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Jeanne Lunford-Solis...

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FRL 2013.03 Helen Palsgraf v. The Long Island Railroad Company (Palsgraf v. Long Island R.R.) New York Court of Appeals - 248 N.Y. 339 (1928) Facts: Palsgraf was standing on a platform next to a railroad that belonged to the Long Island Railroad Company, waiting to board a train that was headed to Rockaway Beach. Around the same time, another train arrived at the station that was headed to another destination. Two men hurried to catch that train. The first man boarded with no problem, but the second man, carrying a small package with fireworks inside, had a little trouble trying to board the train. Two railroad guards tried to help this man from falling, but in the act, the package fell onto the rails, and exploded. This explosion caused some of the railroad scales to strike Palsgraf and injuring her. Palsgraf sued the railroad company for these injuries. Issue: Was the railroad itself responsible for the injuries sustained to the plaintiff, caused by the guard pushing the man with the package? What if the injury caused to the plaintiff was not reasonably foreseeable? Rule: The plaintiff must prove that there was negligence involved, by displaying the elements of duty, standard of care, breach of duty, cause-in-fact, scope of liability, and damages. A defendant owes a duty of care only if the plaintiff is in any sort of reasonable and foreseeable region of harm resulting from the defendant's actions. Analysis: The majority opinion of the court was presented by Judge Benjamin Cardozo, and to sum up his argument, there was nothing to indicate that the dropped package would have caused an explosion. It is important to note that the defendant’s employee was only trying to help the speeding man board the train, and had no idea that the package the man was carrying had any sort of dangerous materials in it. Thus, the actions by the employee cannot be viewed as negligent because of a lack of any foreseeable harm to anyone, including the plaintiff. If the defendant could have foreseen any harm to the plaintiff, however, the only party that would be held liable for negligence would have been the defendant, not the railroad guards because there is absolutely no connection between the guards and the plaintiff’s injuries. In fact, the only person that could realistically bring a negligence case against the railroad, it would be the man who was the owner of the exploding package. A plaintiff can only sue if there was harm against his or her own body or property in regards to range of negligence, and cannot sue for harm performed on another person. On the outside, the package looked perfectly normal, since most people usually carry with them some sort of baggage or package with them when traveling on a train. Even if the railroad guard had threw down the package on purpose, given the appearance of the package, it would not have been viewed as an “unlawful” harm against the plaintiff. On the other hand, however, Judge Andrews argues that the railroad was negligent because there was a cause and effect relationship between the dropping of the package and the plaintiff’s injuries. In addition, if the guard had not acted negligently and the package was not dropped, then there would have been no injury inflicted upon the plaintiff. The judge further continues his

argument by stating that the “duty of care” not only reflects on certain individuals, but rather on society as a whole. In other words, one has a duty to protect the general public from any unreasonable threats. Thus, Judge Andrews’ argument summed up is that there was a cause and effect relationship between the conduct of the guards and the plaintiff’s injuries. Conclusion: Both the trial-level court and the Appellate Division of the Supreme Court in the Second Judicial Department of NY came to a conclusion that the railroad’s employees acted negligently which caused the package of fireworks to explode and injure the plaintiff. Thus, both the trial and appellate court ruled in favor of the plaintiff. The defendants, in turn, appealed to the Court of Appeals of New York, where the decision was eventually reversed. The Court of Appeals came to a conclusion that there was no negligence because there was absolutely no way that the defendants could have reasonably foreseen the injury inflicted on the plaintiff caused by the railroad guards’ actions....