Transcript for:
Understanding the Palsgraf Case and Its Implications

thanks to curiosity stream for keeping legal eagle in the air by clicking the link in the description you'll also get nebula for free the streaming platform made by and for creators like me a platform guard rushes to give him a helpful push from behind that push ensures that he makes it onto the train but it also knocks the box out of his arms so what's in the box what's in the box Harry when are you responsible for an accident imagine you're driving along and you stop at a red light a car then rear-ends you and sends you flying into the car in front of you who's responsible if you hadn't been there there wouldn't have been an accident but does that put you on the hook legally speaking if you knock down one Domino are you responsible for all of the other dominoes falling when a butterfly flaps its wings the effects echo outward like ripples on a pond and no one knows where the effects will stop and what point though do we say that the butterfly caused the harm at what point do we say that the downstream ripples are too attenuated to pin it on the butterfly when someone's sloppy mistake puts your life and limb at risk who must pay what duty do we owe each other that's the question that we must answer in the case of poor mrs. pulsecraft she never saw it coming [Music] submitted for your adjudication our story begins innocently enough with a family trip to the beach the year is 1924 the place Brooklyn New York on a hot and muggy August morning Helen Palsgraf prepares to take her two daughters on a long-awaited trip to Rockaway Beach the girls have been on their very best behavior for weeks helping around the house working tirelessly at their jobs in the nearby clothing factory they diligently counted down the days to today they earned this break from the tiresome monotony of the daily grind mrs. Paul's graft to worked hard to have this rare day off she works two full-time jobs doing back-breaking work both as a housekeeper and as a janitor she rarely sleeps instead painstakingly saving every penny earned to scrape just enough together to be able to afford the train fare and take the girls out for one summer day it was meant to be a respite a breath of fresh air in every sense but fate had other plans having meticulously packed their bags the Palsgraf family slowly makes the trek over to the Atlantic Avenue train station at the ticket booth mrs. Paul's breath pauses briefly considering the expense of the tickets she looks down at her children's filthy but beaming faces their smiles are well worth it she dutifully hands over her hard-earned wages and purchases three tickets on the Long Island Rail Road destination Rockaway Beach the women make their way down to the train platform as they patiently stand in the sweltering heat waiting for their train to arrive they daydream about the sand the surf fresh air that await them little did they know they would never reach their destination meanwhile several blocks away a man is abruptly awoken by the thump-thump-thump of his landlord's fist pounding on his door will call this man Hot Mess Harry Harry starts this morning like most warnings running two steps behind he is over selecting he is three months late on the rent and knows that his landlord is inching ever closer to fulfilling his frequent promise to break his legs if he doesn't come up with the money soon in just in case he has momentarily forgotten the landlord reiterates the point barking through the door to come out and that he knows he's in there Harry scoops up his rumpled clothes from off the floor and throws them on as quickly and quietly as possible he hops around the room shoving his feet into his shoes while trying to simultaneously button his shirt he turns raises the bedroom window and prepares to sneak out down the fire escape but he pauses and doubles back to grab a large box before hang out through the back box in hand Harry now tears down the street and into the train station leaving a path of chaos and destruction in his wake come hell or high water he has to make it to the Train but Harry pauses for a moment at the bottom of the stairs leading up to the train platform panting he swears to himself wishing that he weren't being slowed down by the weight of this inconvenient parcel it's heavy but he's got to get rid of that damn box just then he catches a glimpse of the Train it's already here he picks up the pace throwing caution and innocent bystanders into the wind as he Sprint's up the stairs the train crew is making their final preparations to leave the station this is gonna be a close one he reaches for the Train just as the doors begin closing the crew pity him but time in the Long Island Rail Road wait for no man Harry makes a desperate leap onto the now moving train a platform guard rushes to give him a helpful push from behind that Bush ensures that he makes it onto the train but it also knocks the box out of his arms so what's in the box what's in the box Harry fireworks legal eagles the box is chock-full of fireworks and what happens next depends on who you ask it's a narrow way in the first scenario the train employees push knocks the box out of Harry's arms and into the air for a moment it seems to float suspended in midair but then it begins its inevitable descent downward taking an unlucky bounce off the very edge of the platform it ricochets off and bounces again this time off the side of the train itself and then continues bobbling its way down onto the train track cavity itself where it eventually settles into its final resting place lodged between the two track beams inches from the train wheels which have begun to move out of the station at this point it's worth noting a piece of metal on the undercarriage of the trains caboose which loosened over the years of wear and tear juts out ever so slightly to one side perfectly aligned on a collision course with the box this metal occasionally scrapes against the tracks creating a burst of screeching sparks when it does and just as the caboose passes near the box the metal meets the track again the ensuing spark set off just one firework at first then another until like popcorn all of the fireworks go off in a rapid succession the explosion causes a stampede as panicked passengers push and shove their way towards the exits luggage is left behind knocked over first open and trampled on undershirts nightgowns toiletries are strewn about the floor people shout trying to find their loved ones in the thick smoky fog in the middle of it all mrs. Paul's Graff blindly searches for her way out she cannot see the man fumbling pastor who himself unable to see knocks into an enormous floor scale at just the right angle to cause the scale to topple over and it comes down right on top of poor mrs. Paul's graph that's right folks an industrial heavy brass guess your weight old tiny scale though not so old-timey for mrs. Paul's graph the scale is coin-operated and those coins now begin to slowly trickle out clunking her right on top of her head as it slowly crushes her with all of its mighty weight or the second scenario maybe it happened like this the train employees push knocks the box out of Harry's arms the box a veritable powder keg immediately explodes upon impact on the ground floor so the explosion is so powerful that it knocks the scale next to mrs. Paul's graph over and it falls right on top of her with its mighty weight either way these particular facts are unimportant the point is that mrs. Paul's graph is badly hurt her daughter's rushed to her aid still pinned under the crushing weight of the scale she meekly tells them that she's very sorry but she doesn't think she'll be able to join them at the beach today she's in shock and denial unable to yet comprehend that her life has been irrevocably changed she suffers bruises all over her body and experiences chronic headaches doctors will later diagnose her with traumatic hysteria she develops a stammer and becomes depressed she is no longer able to work and must give up both of her jobs she requires expensive medicines and brown the clock hair her bones eventually heal but mrs. Palsgraf is never quite the same when she is lucid enough to recount the events of that fateful August day and helplessly watch the medical bills pile up she is above all else angry but this is America and someone has to pay for what happened to her but what about Hot Mess Harry while clearly he's at fault here and should be liable for the damages that's not what this story is about Harry never paid mrs. Palsgraf a dime for two reasons one he didn't have any money and two he was never seen or heard from again and even if mrs. Palsgraf were able to track him down and he were served with a lawsuit he would have been useless to her he's what we call judgment proof meaning that he wouldn't have had the funds to cover a judgment against him in any case this is often a sad reality about litigation and with nowhere else to turn mrs. Paul's Graf sues the Long Island Railroad company she claims that the railroad was negligent when its employee pushed Harry on to the train and although Harry is primarily at fault she was also harmed by the negligence of the railroad company at trial a jury Awards her six thousand dollars in damages around $900,000 by today's standards but the railroad appeals mrs. Paul's Graf wins again and finally the case makes its way all the way up to New York's highest court the Court of Appeals the issue on the table was the Long Island Railroad Company negligent towards mrs. Palsgraf could they have foreseen that someone would bring fireworks on the train in other words what exactly is negligence we now turn to Albany where courtroom proceedings are just getting underway this Court has had the opportunity to review the record our counselors ready for oral argument yes your honor William McNamara representing the appellant the Long Island Railroad company Matthew would sir representing the appellate mrs. Helen Paul's graph ok then gentlemen let's get started thank you and may it please the court your honors my client the Long Island Railroad has been accused of negligence toward Helen Palsgraf when one of its employees helped a passenger onto his train by giving him a supportive nudge aboard there was no negligence here how could we possibly expect that employee to know that the Box in the passengers arms was packed with fireworks there was no signage or any other sort of indication that the box contained dangerous contents there was simply no way for a reasonable person to know that if this particular box were dropped it would explode my client was not negligent on the contrary the employee was doing the right thing don't we want to live in a society in which people feel able to help each other rather than second-guess every move they make and fear of future liability the passenger is the only one to blame here your honors and the railroad was clearly negligent here the employee pushed the man out of the Train far too hard his carelessness forced the passenger to drop the box which directly caused the explosion that has devastated for mrs. Palsgraf if not for the railroads actions mrs. Paul's graph would not have been injured it's a logical certainty mr. McNamara let's assume that the railroad employee was in fact negligent here with regard to the passenger would mrs. Palsgraf be entitled to damages your honors even if we accept that there could have been negligent gents in how the employee helped the passenger board the train that remains a matter exclusively between the passenger and my client mrs. Palsgraf just has nothing to do with it your honors my client has everything to do with it she did everything right that fateful August day she was a paying customer on the Long Island Rail Road who obeyed all the rules minded her business and waited exactly where the railroad told her and what exactly would you suggest that the railroad owes to paying customers councilor and the railroad owes mrs. Palsgraf and all of its customers a duty of care and it breached that duty when its employees negligence created an unsafe environment causing my clients harrowing injury if an injury can be traced back to a wrongful act and there are no intervening events that is sufficient to establish liability but if we hold the railroad negligent to mrs Palsgraf where do we draw the line we simply cannot hold my client responsible for the consequences of all actions no matter how extraordinary or bizarre that impact customers of the railroad the duty of care must be limited to those who are reasonably foreseeable under the circumstances counselor don't you think that mrs. Powell's Graf's injuries were reasonably foreseeable though regrettable her injuries were not foreseeable who could know that the box would explode upon falling and that that explosion would knock over a scale all the way across the platform and that scale would somehow topple on top of her the chain of events here is too tenuous but my client was foreseeable Your Honor she was in the zone of foreseeable danger mrs. Paul's graphs close physical proximity to the careless Act matters here she was waiting on the designated platform for her imminent train about 10 feet from the site of the explosion she was clearly at risk of direct physical impact mr. McNamara what do you say to that even if we accept the zone of danger test mrs. Palsgraf was still too far away from the explosion to have a successful negligence claim under that standard it is definitely not reasonably foreseeable that a scale all the way on the other end of the station could fall on top of her as a result of one employees careless push there are just too many variables in between the two occur thank you gentlemen this matter is adjourned chief judge and future Supreme Court justice Cardozo wrote the decision of the New York Court of Appeals in what is considered by many to be the single most influential torts case in all of American jurisprudence do you have what it takes to think like a future Supreme Court justice pause this video put on your favorite black robe and grab your gavel and let me know in the comments how you think this case was decided all wait Cardoso sided with the railroad company and found that they did not have a duty of care to mrs. Palsgraf her injuries were not reasonably foreseeable because the explosive box didn't appear to be dangerous and a reasonable person would not have foreseen that a scale would topple on top of mrs. Palsgraf as a result of the box falling and exploding not only was her judgment reversed but mrs. Paul's graph actually ended up owing the Long Island Railroad company five hundred and sixty dollars to cover their attorneys fees the equivalent of a year's worth of her wages this case is probably the most famous American tort case in all of jurisprudence its legacy however has eroded over time the dissents in this case found that because there was little to no gap in time or space between the train employees negligence and mrs. paul scraps injuries the injuries were a natural consequence of the series of events that followed and while some states still follow Cardozo's approach and find no liability for an unforeseeable plaintiff most states now agree with the dissent and focus on the proximity and time and space to the negligence and the plaintiffs injuries this true crime series is a huge experiment for this channel I hope you like it because it takes about ten times longer than all of my other normal videos this is a huge experiment because sometimes publishing on YouTube is risky this video in fact probably got demonetized which is why my creator friends and I teamed up to build our own platform where creators don't need to worry about demonization or the dreaded out it's called nebula and we're thrilled to be partnering with curiosity stream nebula is a place where creators can do what they do best create it's a place where we can both house our content and free and also experiment with original series that probably wouldn't work on YouTube in fact if you liked this episode of the K sub you can find an extended version that I actually can't show on YouTube it's League legal but now with 10% more murder and when I said nebula is built by creators fourth graders I really mean it nebula features lots of YouTube's top education creators like Lindsay Ellis Joe Scott Kent obento Kirk azad and tons of others we get to collaborate in ways that wouldn't really work on YouTube for example the nebula exclusive series called working titles where every episode a different creator breaks down their favorite TV intro sequence recently Thomas Frank did gravity falls now you see it covered the Simpsons and I'll be doing Law & Order very very soon seriously we worked really hard on this and we're all really proud of the results the project is self-funded not backed by investors and we've managed to make this ad free and with no dreaded algorithm so what does this have to do with curiosity stream well they love educational content and educational creators so they're the perfect partner for nebula and we just recently worked out a deal where if you sign up for curiosity stream with a link in the description not only will you get a free one-month trial for curiosity's dream but you'll also get a subscription for nebula for free and to be clear that doesn't expire that nebula subscription is not a trial it's free for as long as you have a curiosity stream subscription which means that for less than 20 bucks a year not only to get unlimited access to curiosity streams massive library of gorgeous high budget documentaries but you'll also enjoy the private playground of youtubers best educational creators at no additional charge and you'll be supporting creators like me directly so just go to curiosity stream comm slash legal eagle so if you click on the link in the description not only will you get access to curiosity stream including my favorite documentary Peter sagal 'he's history which explains how some of the pivotal events in US history are tied to money like Watergate and the Civil War but you'll also get access to nebula for as long as you have a curiosity stream membership so just click on the link below and get curiosity stream and nebula together you'll be supporting creators and education so what do you think do you agree with my analysis leave your objections in the comments and check out this playlist over here that has all of my other true-crime videos including the case of the shotgun booby trap and the case of the genius murderers Leopold and Loeb so click on this playlist and I'll see you in court