P bought a ticket on D's train and was waiting to board the train.
Men were hurrying to get onto a train that was about to leave. One man was carrying a nondescript package. Guards for the D tried to help the man get on the train, and the man dropped his package onto the tracks.
The package contained fireworks which exploded when they hit the ground.
The force of the blast was so great that it destroyed part of the platform and caused some scales to fall. One of the scales hit the P.
P sued D in negligence.
Procedural History:
Trial court found for P.
Appellate court found for P.
NY COA reversed, complaint dismissed.
Issues:
How should a court determine whether a duty of due care is owed to a party?
To whom does a party owe a duty of care?
Holding/Rule:
A duty that is owed must be determined from the risk that can reasonably be foreseen under the circumstances.
A defendant owes a duty of care only to those who are in the reasonably foreseeable zone of danger.
Reasoning:
No one was on notice that the package contained fireworks. D was negligent in regard to the man carrying the package since he was close but not to P who was at the opposite end of the tracks.
In order to support a finding in negligence, it must be proved that D owed P some duty of care. The duty of care only extends in this situation only as far as a reasonable person could foresee.
Even if the guard had thrown down the package, D would not be liable to P since a reasonable person could not foresee P's injury.
Dissent:
This issue should be handled according to proximate cause. There was a natural and continuous series of events which led to P's injury.
Remoteness in time or space can be looked upon by courts as inviting some sort of intervening force between the cause and effect. Here, there is little to no remoteness between in time or space.
Everyone owes everyone else in the world the duty of refraining from acts that may unreasonably threaten the safety of others.
