Issue
Whether a railroad owed a duty of care to a plaintiff injured by distant consequences that were not reasonably foreseeable from the employees conduct.
Holding
The court held that negligence requires a duty owed to the injured plaintiff, and the harm to Palsgraf was not within the reasonably foreseeable zone of danger.
Facts
Railroad employees helped a passenger board a moving train. The passenger dropped a package containing fireworks, which exploded and caused scales at the other end of the platform to fall on Palsgraf.
Rule
Negligence is not actionable unless the defendant owed a duty to the plaintiff. Duty depends on whether the plaintiff was foreseeably endangered by the conduct.
Reasoning
The court reasoned that the employees may have acted carelessly toward the passenger carrying the package, but that did not create a duty to every person on the platform. Because Palsgraf was outside the foreseeable zone of risk, the railroad was not liable to her.