Palsgraf V. Long Island Railroad

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Helen Palsgraf was standing on a Long Island Rail Road (LIRR) platform in New York City, waiting for a train to take her and her two daughters. While she was waiting for her train, another train pulled in, and two passengers came running across the platform to catch it. One of the passengers was carrying a package under his arm. The train began leaving the platform, and two LIRR employees (one on the train, one on the ground) attempted to help the passengers get on board while the train was moving. As they pulled the passengers onto the train, the package fell to the platform.

Unbeknownst to the railroad workers, the package contained fireworks. The men were on their way to a celebration in Queens, and had brought several rockets with them to light up. As soon as the package hit the ground, it exploded. The explosion could be heard several blocks away; a stampede erupted on the crowded platform as people began running.

Palsgraf, at the other end of the platform, was not hurt by the explosion itself. Rather, the explosion knocked over a large scale next to Palsgraf, which fell on her and struck her in the arm, hip, and thigh. She was able to walk with great difficulty, but was unable to continue her job as a housekeeper, and began suffering from shock-related symptoms a few days later, including stuttering. Palsgraf prepared the case against the Long Island Railroad. LIRR argued that its employees had not been negligent in the events that led up to Palsgraf's injury. They did not know what was inside the package, and therefore had no reason to be particularly careful about it falling to the ground. In their appellate briefs, Palsgraf and the railroad disagreed over what the employees in question were exactly doing. Palsgraf maintained that they were pushing the passengers onto the train; the railroad said the passengers had jumped on the train, and that the…...

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