## Facts

- Helen Palsgraf stood on a Long Island Railroad platform after purchasing a ticket.
- As a train stopped, two men ran to board; one boarded safely and the other carried a small, newspaper-wrapped package.
- The second man appeared unsteady while boarding; a guard on the train pulled him in as a guard on the platform pushed him from behind.
- The package was dislodged, fell onto the rails, and exploded; nothing about the package indicated it contained fireworks.
- The explosion toppled a coin-operated scale at another part of the platform, which fell onto Palsgraf and injured her.

## Issues

1. Whether the railroad’s employees owed Palsgraf a duty of care extending to the risk that a dislodged, ordinary-looking package would explode and injure a distant bystander.
2. Whether negligent conduct toward the passenger with the package can support liability to a plaintiff outside the reasonably foreseeable zone of danger.

## Decision

- The New York Court of Appeals reversed (4–3) and dismissed the complaint.
- The court held the railroad was not liable because the employees’ conduct, even if negligent toward the passenger, was not negligent as to Palsgraf.
- The court reasoned that the injury to Palsgraf was not within the risks reasonably foreseeable from the employees’ actions, given the package’s innocuous appearance.

## Legal Principles

- Negligence is relational; liability requires breach of a duty owed to the particular plaintiff, not “negligence in the air.”
- The scope of duty is defined by foreseeable risk: “The risk reasonably to be perceived defines the duty to be obeyed.”
- If a plaintiff is outside the range of apprehension created by the defendant’s conduct, the defendant has not breached a duty to that plaintiff, and liability does not attach.
- A duty-based limitation may resolve cases without reaching broader proximate-cause line drawing where no duty exists to the injured plaintiff.

## Conclusion

The court held that the railroad owed no duty to Palsgraf with respect to the unforeseeable explosion and resulting injury because she was outside the foreseeable zone of danger created by the guards’ assistance to the passenger, requiring dismissal despite a jury verdict for the plaintiff.


Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 162 N.E. 99 (N.Y. 1928)