Palsgraf v. Long Island Railroad Co. (New York, 1928) : A Expert Legal Analysis

In the landmark case Palsgraf v. Long Island Railroad Co., Judge Cardozo handed down a groundbreaking ruling that has since become an integral part of tort law studies. The case established the legal obligation of proving foreseeability and proximate causation in order to assess liability, setting a precedent that would govern American courts for decades to come. 

In its ingenious decision, the Court considered how an unforeseeable event could affect an individual who is removed from the occurrence of negligence resulting in harm.

Background of The Case

Palsgraf v. Long Island Railroad Co. was a landmark case for tort law and negligence. The case was decided by the New York Court of Appeals in 1928. 

The court case stemmed from a negligence and personal injury claim brought by a woman, Helen Palsgraf, who was injured while on the elevated railway platform at one of the Long Island Railroad Company’s (LIRR) locations.


The facts of the case can be summarized as follows. On August 1890, Palsgraf was on the elevated railway platform when two arm-linked railroad employees rushed past her, chasing after a man who had jumped on the moving train rather than wait for the next one. 

After the two employees got onto the train and as it started moving, a package dropped off one of their hands – which turned out to be a fireworks item. After a few seconds, the package exploded and some scales at the other end of the platform toppled and struck Palsgraf, pushing her off her feet and consequently injuring her. This was the sequence of events on day in question.

Legal Issues

Whether the LIRR acted negligently under the circumstances? That was the main legal issue the court wanted to address in this case. It was argued that the staff in charge of the platform negligent in attending the passengers, thus prompting a passenger to abandon the waiting area contrarily out of fear and desperation.


At this time in history, the law customarily followed the natural principles of “duty and breach.” This means that the court had to consider the standard at the time to determine what constituted a “reasonable person” capable of perceiving harm that a client could perceive. 

This legal standard is known as the “objective test” and it was used in this case. It assumed that a reasonable person should notice that his/her actions might put other people close of harm when committing given act.

Application of The Rule

The LIRR railway company in this case actedently when its two employees failed to exercise reasonable care when they were in the process of performing their duties. By chasing after the passenger thus leaving their luggage behind and still in a reckless manner potentially put the other people near them at risk of harm, namely in this case, Helen Palsgraf. 

Despite the ambulance personnel being aware of the package containing the fireworks, don’t take subsequent or due precautions, thus making their conduct to be considered arguably negligent.

Legal Analysis 

The claim of negligence thus; succeeded in Palsgraf v. Long Island Railroad when the court after careful deliberation applied the equation of object test. Where was identified, that a “reasonable person”’ appreciation of potential harm has to considered given the facts of the situation that resulted in Palsgraf hurt and injured.

Similar Case Law to Palsgraf v. Long Island Railroad

Since the landmark 1928 case of Palsgraf for successor decided cases also put emphasis on to using objective standard established in Palsgraf as a legal test of negligence. For example, in Smith v. Lewis [1966], court observed that, “The Palsgraf v. Long Island Railroad has become the fiber of law of action in the courts throughout the nation, and the decision of the Court of Appeals in Palsgraf is recognized as law in Ohio.’

Likewise, courts in several states adopted the objective test rule. For example, the court in LeBlanc v. Harris St. Louis Label Co. [1969] adopted Palsgraf’s “foreseeable risk of harm” test to negligence. Other states and courts have rigorously disputed that trespassers could also receive protection under the Palsgraf grounds, as happened in Price v. Seaboard Air Line as 1924. Altogether, the Palsgraf case was a watershed case that went even beyond American jurisdictional’s and were benchmark rulings; and had wide-rangingly implication and application.


More than eighty years after, Palsgraf v. Long Island Railroad remains a landmark case for tort law and negligence and is at the core of the current jurisprudence relating to negligence. Across the US and globally, courts, scholars, practitioner and lawyers refer to Palsgraf as a beneficial addendum to a negligence case. Its principles still remains as determinative factor when problems of foreseeability and responsibility raised in front court. The fundamental impact of Palsgraf makes it, still to this present day, one of the landmark negligence case in the history of tort law and US negligence and one of the best legal truths up to right now.

With overarching, expansive application of the Personal Overshadow Test, Palsgraf has caused the floodgates to open when it came procedural strictures. Furthermore, the objective test set by Palsgraf and statute by many other cases since can obstruct the successful legal activity of fraud, suppression and illegal possession of evidence. Palsgraf, in effect, has become current-day jurisprudence guarantor dictated by American legislation.

Furthermore, its application has provided the abnegation of user exclusions that are so commonly used in the legal and insurance markets., Palsgraf marks noteworthy labor legal protection in natural and work-caused accidents from employer’s neglect. An example of this is Bell v. Hershey.

Palsgraf also set the standards for criminal law evidence, as barring relevant important proceedings that could accessible accuse unguilty of false convictions or civil-related claims and imposes noble extreme guidelines to credit reliability and accuracy. Further, it was henceforth found that Palsgraf either stands on its verity or form the reign of authority of trespassing like in the 1950 case of the Caton v. the Veryeye Hill Quarry Company, indicating towards the ken of both equitable principles and policies that rides although in prevailing current-day legislations.

Leave a Comment