Helen and Grace are on a subway train on the way home from an office where they work together. Both are standing near one of the doors of the crowded train. Suddenly, the door opens while the train is moving and Helen falls out. Moments later, the train stops when the driver realizes what has happened. (Assume that the reason the door opened was negligent maintenance by the subway). Grace watches in horror as Helen falls out the door. When the train stops, Grace immediately climbs down through the open door onto the tracks in order to help Helen. As Grace searches in the dark, she slips on a live rail and dies from electrocution. Luckily, Helen finds her way to safety with only minor injury. Helen and Grace's estate now brings separate negligence actions against the subway. Focus solely on the issue of duty.

1. Under the majority (Cardozo) opinion of Palsgraf, did the subway owe a duty to Helen? Explain. To Grace? Explain.
2. Under the dissenting (Andrews) opinion of Palsgraf, did the subway owe a duty to Helen? Explain. To Grace? Explain.

https://www.nycourts.gov/reporter/archives/palsgraf_lirr.htm (The Palsgraf Case)