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For Cardozo, Mrs. Palsgraf’s claim failed for a more fundamental reason than want of proximate cause: The train attendant’s negligence toward the boarding youth was not negligent toward Mrs. Palsgraf, since she was not a foreseeable victim.78 “Negligence . . . is . . . a term of relation”79: To commit the tort of negligence is to (foreseeably) injure someone by breaching a duty to take reasonable care as to her. More generally, unless a defendant breaches a duty owed to the plaintiff — that is, commits a wrong against her — the Palsgraf perspective maintains that the plaintiff cannot recover for any resulting injuries, because redressing relational wrongs is tort law’s fundamental purpose.
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