Let’s assume for a moment that a train commuter is racing towards a slowly moving train that is just starting to depart from a station. As the commuter sprints across the platform, a conductor reaches out in an attempt to pull the commuter onto the train. A second railroad employee tries to push the commuter onto the train.
Unbeknownst to the conductor and the employee, the commuter is carrying a package containing fireworks. In their attempts at helping, the conductor and employee actually cause the commuter to drop her package. The fireworks hit the ground, explode, and cause substantial damage to the train station.
A woman standing at the opposite end of the platform suffers substantial injury from the explosion. She later sues the railroad company. What’s the result? Sure, it seems at first glance that the conductor and railroad employee were somehow responsible for the injuries. But, did they actually cause them?
Introducing Legal Causation
Legal causation is an essential element in every personal injury claim. What does this mean? Well, in personal injury actions, it’s not enough for a plaintiff to simply assert that she suffered an injury for which a defendant must compensate her for. Rather, a plaintiff must prove that a defendant caused the injury in question.
This concept is known as legal causation. Further, the law carves out two specific types of legal “causes.” The first is referred to as “cause in fact.” The second is referred to as “proximate cause.” Both must be proven by a plaintiff in a personal injury action in order to maintain a claim.
Cause in Fact
Cause in fact means that a defendant’s conduct actually caused injury to the plaintiff. A plaintiff can prove this by highlighting facts or evidence that demonstrate a defendant’s act, or failure to act, was a necessary cause of any injury sustained. Put another way, a plaintiff must show that his injury would not have resulted “but for” the defendant’s action or omission. If an injury would have resulted regardless of a defendant’s actions, then “cause in fact” cannot be proven and a defendant cannot be held liable for damages.
This one can be a bit tricky. In addition to cause in fact, a plaintiff must prove that an act was the proximate cause of an injury. A proximate cause deals with the relation of an event to a specific injury. The most common legal test for determining proximate cause is based upon foreseeability. This means that an act is the proximate cause of an injury if the injury could have been reasonably predicted, or foreseen, from the alleged act.
An example here will help clarify. Let’s assume boy #1 throws a rock at boy #2 and injures his nose. Proximate cause here is met since a reasonable person could have predicted that throwing a rock at someone would cause bodily injury.
Now, let’s assume boy #2 is standing in front of a shelf that supports a few picture frames. Boy #1 winds up and hurls the rock at boy #2. Instead of the rock directly hitting boy #2, the rock hits a picture frame, knocks it off the shelf, and the frame strikes boy #2 in the nose. Here, proximate cause it still met since a reasonable person could have predicted the specific accident and injury.
Palsgraf v. Long Island Railroad
The factual scenario provided at the very outset of this post is not a fictitious one. The facts are part of a very real legal case that took place in the 1920s. The case in question is Palsgraf v. Long Island Railroad. The case is still debated in law schools and scholarly legal articles to this very day.
Using our newly found knowledge on legal causation, let’s return to the facts of this case. The injured woman was one Mrs. Palsgraf and she sued Long Island Railroad after fireworks in a commuter’s bag caused an explosion. Did the railroad company legally cause Mrs. Palsgraf’s injuries? It’s okay to take some time. You can even re-read the content provided above for assistance.
And, the answer is? No. The court denied Mrs. Palsgraf’s case on the basis of proximate cause. It ruled that Mrs. Palsgraf’s injuries were not reasonably foreseeable to those employed by Long Island Railroad. See, legal causation can actually be fun, right?
Well, maybe not for us all. But, keep in mind that the Phillips Law Firm consists of some very bright and knowledgeable attorneys. They enjoy these tests of legal insight. They are also passionate about applying their legal acumen to your individual case. Please, if you have been injured in an accident, contact our firm today. Our dedicated team of attorneys will answer your questions and assist you in seeking the justice you deserve.