The case of Palsgraf v. Long Island Railroad Co. revolves around concepts of negligence. The proximate cause in the case points towards negligence law. According to Ben–Shabar, 2016, proximate cause involves establishing a connection between the conduct of the defendant and the injuries on the plaintiff. The wounds on the plaintiff should be the predictable or foreseeable outcomes of the defendant’s actions. A successful plaintiff’s case must prove the elements of negligence in the case, which mainly lies in damages or injuries. This analysis seeks to review the case considering negligence, unforeseen harm, and the historical concept that influenced the court’s outcome.
The elements of negligence in the case of Palsgraf v. Long Island Railroad Co are as follows;
Duty of care to Mrs Palsgraf.
It entails whether the defendant had a duty to care for the plaintiff. According to Zipursky, 2014, the law should be able to recognize the relationship between the defendant and the plaintiff to conclude whether there is any duty of care that should be given or owned by the plaintiff. In the Palsgraf case, the Long Island Railroad Co. had a task to ensure the safety of its passengers and other people around the train by establishing safety standards to prevent foreseeable harm. A defendant fails to exercise the duty of care through their inability to care for the plaintiff, which can be further determined as a breach of duty of care. The duty of care is an obligation normally imposed on a person person who requires adherence to a reasonable standard. This is normally used to avoid any form of careless action which may lead to injury or harm.
Damage or injury
In a negligence case, the plaintiff should showcase a harm that is legally recognized. Mrs Palsgraf had been bruised and shaken, as confirmed by her doctor in court. She had undergone medical treatment for traumatic hysteria, which was directly related to the explosion at the railroad (Little, 2007). Through her lawyer, the plaintiff could vividly describe the injury caused.
Actual cause of injury and proximate cause of harm
Negligence cases often seek to prove that the defendant’s actions were the immediate cause of harm or injury to the plaintiff. The defendant must strive to prove that it was not their responsibility or that the responsibility was not directly connected to them. If the defendant’s damages are not within the scope of the threats that could be foreseen, then the plaintiff cannot prove that the defendant indeed caused the injuries. Mrs.Palsgraf had the necessary proof as she had sought medical attention regarding the bruises and had her doctor as a witness.
The legal status of Mrs.Palsgraf as she waited for the train was an invitee. An invitee is a person who, through the owners’ gratification or express as allowed into a property for business purposes. Since Mrs.Plasgraf had purchased the tickets and intended to travel by railroad, it shows the railroad had granted her permission in their vicinity. As an invitee, the railroad company was mandated to care for Mrs.Palsgraf. It is critical to analyze the legal status of Mrs.Palsgraf because the status determines the duty owed to her by the railroad company. A trespasser is not entitled to a significant duty of care since it describes a person who enters a land or a building without the owner’s consent.
On the other hand, a licensee is entitled to some protection since it describes people who enter a property but do not have a commercial relationship with the property or building owner. An invitee has the highest protection in the law compared to a trespasser or a licensee. The analysis of the legal status assists in putting in place a framework that a defendant must exercise to ensure they reasonably care to prevent the occurrence of harm. It is also evident that the occurrence amounted to relationship distance between the two parties.
Foreseeability is one of the critical elements in a negligence case. It analyses whether the defendant could see the actions and determine whether they can cause the plaintiff harm, damage, or injury. The basic principle in foreseeability states that claims for damages or injuries are limited to what the nonperforming party foresaw or could have foreseen at the time of occurrence. In Mrs.Palsgraf v the Long Island Railroad Company, it is challenging to state whether the activities and actions of a man with fireworks could have caused harm. Also, the court would look at the foreseeability of a person near the scale and their likelihood of being injured by an explosion caused by a dropped package. It was unforeseeable for the railroad company for such injuries to happen.
The court’s predisposition to favor railroads certainly worked against Mrs. Palsgraf’s case. In the 1920s and 1930s, the railroad was the most significant transport mode and ensured the nation’s stability. The railroad was one of the leaders on the stock board, and its income had begun to decline unsatisfactorily. The great depression hit the nation around the time the mentioned case took place when the railroad had gone bankrupt. There was a dire need to save the railroad, which had reduced its earnings, and further additional costs would have rendered it nonfunctional. The railroad faced automobile competition and had to reduce its prices to attract passengers. The public invested heavily in automobiles, increasing the predicaments for railroads, which were already worn out due to the effects of World War II. The court was influenced by public policy and careful deliberation of the economic struggles. It was more inclined to help the railroad overcome its financial struggles, thus limiting Mrs.Palsgraf from being successful in her claim.
In conclusion, the case above shows critical yet very complex elements of negligence. The duty to care, damages, and injuries, Mrs. Palsgraf’s legal status and its significance, foreseeability, and the factors surrounding the occurrence of the case influenced the court in settling for the verdict. Consistency of the above elements is necessary as they provide detailed information while handling negligence cases. Most of the issues presented in this case are issues that can amount to greater prosecution in a court of law. Most parties here should understand the magnitude of their action because they need that to win the case. Legal handling of this case must be done by someone who understands its magnitude, and proper preparation must be done before the case is prosecuted. From the analysis, there was a dire need to save the railroad, which had reduced its earnings, and further additional costs would have rendered it nonfunctional. The railroad faced automobile competition and had to reduce its prices to attract passengers.
References
Ben-Shahar, O., & Porat, A. (2016). Personalizing negligence law. NYUL Rev., 91, 627.
Little, J. W. (2007). Palsgraf Revisited (Again). Pierce L. Rev., 6, 75.
Zipursky, B. C. (2014). Reasonableness in and out of Negligence Law. U. Pa. L. Rev., 163, 2131.
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