Consider how this understanding of tort law deals with the facts in Palsgraf itself. The freakish outcome that Mrs. Palsgraf suffered, as a result of the train attendant’s negligent treatment of the youth attempting to board his train, was not a foreseeable result of that negligent action.75 Thus many scholars and judges have supposed that Mrs. Palsgraf’s claim fails simply for want of proximate cause (which, to a rough approximation, requires that the plaintiff’s injury be the foreseeable materialization of the risk that made the defendant’s action wrongful).76 As defenders of the Palsgraf perspective note, however, treating Palsgraf simply as a proximate cause case does not comport with Cardozo’s reasoning in the opinion itself.77
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