Palsgraf v. Long Island Railroad Company
The Case of Palsgraf v. Long Island Railroad Company is a landmark in American tort law. The facts of the case are relatively simple. Helen Palsgraf was waiting or a train when two men raced into a cabin in a departing train. Two employees helped one of them on the train, but in the process, his baggage fell and exploded (apparently due to the presence of fireworks). 31 people were injured in the explosion, and people ran away in panic.
As a result of the commotion, a large coin-operated scale hit Helen Palsgraf. The plaintiff claimed that she had developed a stutter as a result of the incident.
According to New York law at the time, the liability standard was the classical one. If the plaintiff was going to collect, she would have to prove that the Long Island Railroad Company had a duty of care towards Ms. Palsgraf and that it had been breached. The Appellate Division of the New York Supreme Court found in favor of the plaintiff, finding the railroad workers neglect to have contributed substantially to her injuries.
The Long Island Railroad Company took the case to the New York Court of Appeals, which ultimately found in favor of the railroad company. At the time, Benjamin Cardozo was the Chief Judge of the Court of Appeals. Cardozo was a highly regarded justice at the time, and would eventually be appointed to the U.S. Supreme Court.
His opinion was that the Long Island Railroad Company should not be liable for damages. Cardozo admitted that the railway workers had been negligent in helping the passenger on to a moving train and dropping the suitcase on the ground. However, he argued that they could not reasonably have expected an innocuous-looking suitcase to explode and harm an individual well out of harm’s way.
Cardozo explained the negligent behavior of the railroad workers, concerned the package and the individual carrying it. It did not, however, concern Ms. Palsgraf who was the victim of unpredictable circumstances. Cardozo believed the duty of the railroad was in preventing “the risk reasonably to be perceived defines the duty to be obeyed”. As the Chief Judge put it: “the diversity of incidents emphasizes the futility of the effort to build the plaintiff’s right upon the basis of a wrong to someone else” (434).
The most notable dissenting opinion was put forth by William Andrews. This justice regarded Ms. Palsgraf as a fully-fledged human being. His opinion referred to her as “an intending passenger.” Stating the simple fact that she was there to catch a train and not trespassing or loitering, emphasizes that the railroad company had responsibility for her welfare.
Andrews argued that when an act endangered other people, they are “liable for all its proximate consequences, even where they result in injury to one who would generally be thought to be outside the radius of danger” (436). This is a completely different philosophy of due care from the one espoused by Cardozo. According to Andrews, the relationship was not limited to that between an individual engaging in a dangerous act and those he could reasonably believe would be harmed.
Aside from disagreeing with Cardozo’s general principles of liability, Andrews also disputed his interpretation of the facts of the case. His definition of proximate cause as one that, without which the harm would not have occurred. He adds a further test, that there not be too many intervening causes. (438).
He believed that risky behavior on the platform could easily be predicted to hurt the people on it. As he explained “There was no remoteness in time, little in space. And surely, given such an explosion as here, it needed no great foresight to predict that the natural result would be to injure one on the platform at no greater distance from its scene than was the plaintiff” (439).
I agree with the interpretation given by Andrews, both for moral and legal reasons. In some parts, Cardozo’s interpretation simply seems slanted to prefer the railroad company. The language Cardozo uses regarding the plaintiff is notably dehumanizing. He famously said that “there is an accuracy that defeats itself by the overstatement of details” (433).
Cardozo’s lack of details is more than a stylistic choice, it is a legal one. His abstract decisions remove any trace of humanity from the case. Cardozo did not even refer to her as a passenger or customer of the railroad but rather conceived of Ms. Palsgraf as an individual standing on the platform for no apparent reason. This approach favors the railroad and other big companies, as it diminishes sympathy for the plight of plaintiffs suing them for damages.
The context of the lawsuit and the differences in power between the plaintiff and the defendant. Neither can the deep injustice of the verdict be ignored. Ms. Palsgraf was a very poor woman, working as a janitor and housekeeper. The attempts by Cardozo to dehumanize her, cannot be taken out of the context of social hierarchy.
Despite the injuries sustained by Ms. Palsgraf, the justice referred to her receiving compensation as “the vicarious beneficiary of a breach of contract to another” (433). This completely ignores the harm done to the plaintiff, portraying her as some sort of opportunistic fortune seeker rather than a poor woman suffering from some form of PTSD (which granted, was not a well-understood malady at that time (440).
In this case, Cardozo’s allergy to detail meant that he completely lost track of the social implications of the case. Whether, this is intentional or unintentional is hard to say. Be that as it may, with that attitude, it is not surprising that the court ordered that the destitute and now disabled janitor pay court costs to the tune of $559.60 to the railroad company.
Meanwhile, to Andrews, the social implications of the actions are front and center. Andrews believes that when a wrong is committed, it is a danger not only to those within the predictable radius of damage, but also “a wrong to the public at large” (436). But rather, between those doing harm and those who were harmed in reality. Due care is designed to protect all of society, not just society within a certain radius of feet. Distance is not necessarily relevant to damages. Children may receive damages for the killing of their father without even being present at the scene of the wrong committed.
It is no coincidence that despite being in the minority, it was Andrew’s interpretation that became the dominant one in most states. After all, the main goals of tort law in the United States are to provide relief to harmed parties and punish and deter negligent behavior.
One of the purposes of punitive damages is to discourage further such acts by negligent parties. Sending the message to railway companies that negligent treatment will go unpunished in many cases do not serve the purpose of the law. The Cardozo approach does not address any of these issues and instead wraps its unfair approach in an aura of abstract respectability.
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