Lecture #16 Proximate Cause

Proximate cause is the second part of the element of causation but is better thought of as a separate element of the cause of action.
The concept may be initially challenging, but will become clearer through case analysis.
The session will progress step-by-step to facilitate understanding of proximate cause.

Understanding why courts developed proximate cause clarifies the distinction between proximate cause and cause in fact.
The aim is to grasp the public policy underlying proximate cause.
An understanding of public policy aids in proper analysis for supporting a claim of proximate cause.

Enright versus Eli Lilly
- Important case illustrating the policy reasons for separate consideration of proximate cause.
- Students should relate two quotes from cases in the syllabus (Atlantic Coast Cline v. Daniels and the second discussed in point for discussion number 2) to the facts and court decisions in Enright.

Proper analysis to support a plaintiff's claim of proximate cause will be discussed next.
This analysis includes examining two important case law precedents.

Rape Olemis
- Understand its relation to causation issues.
Palsgraf v. Long Island Railroad
- Landmark case in tort law related to proximate cause.
- Summary of Palsgraf's injury:
  - Mrs. Palsgraf was on a train platform when a man hurriedly boarding a train dropped a package containing fireworks, which exploded.
  - The explosion caused a scale to fall and injure her.
- Court Proceedings:
  - Palsgraf won at trial and appellate levels; the railroad appealed to New York's highest court.
  - Justice Cardozo's Majority Opinion: Railroad not liable as injuries were not a foreseeable consequence of their negligence.
  - Justice Andrews' Dissenting Opinion: Established that a duty to one is a duty to all; liability should exist if injury can be traced back to wrongful act without intervening events.
- Proximate cause limits tort liability to foreseeable results of a defendant's act.
- Students should read the opinions carefully to understand the intricacies of the case.

Following the understanding of the theory, students will analyze Ayers versus Johnson and Johnson.
- Focus on the arguments of the parties and how the court addresses them to illustrate application of causation concepts.
- Importance of taking careful notes for comprehension and future discussion.

This session serves as a preview, guiding students to engage deeply with their reading assignments.
Emphasis on analyzing court cases to enhance understanding of proximate cause and liability in negligence.