[NO NUMBER IN ORIGINAL]
Court of Appeals of New York
248 N.Y. 339; 162 N.E. 99; 1928 N.Y. LEXIS 1269; 59 A.L.R. 1253
February 24, 1928, Argued
May 29, 1928, Decided
Facts:
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