Write an IRAC paragraph based on the following facts, issue, and cases.

Facts

Ms. Jones was waiting to get off the commuter train in the train's vestibule. The commuter train pulled into the station and Ms. Jones descended the stairs to disembark from the train. The conductor exited the train first to watch the passengers exit the train and then signal to close the doors for the train to start rolling. Ms. Jones was carrying her briefcase, which had a long strap. As Ms. Jones exited the train the briefcase strap was behind her. The train doors shut with Ms. Jones on the platform but with the briefcase strap still inside the door. The train dragged Ms. Jones about ten feet and she suffered a broken shoulder. The issue you have to consider is whether the conductor's negligence by signaling for the train to start was the proximate cause of Ms. Jones's broken shoulder.

Issue

The issue on which you should focus is whether the conductor's failure to see that Ms. Jones's briefcase strap was inside the door as he signaled for the train to start moving is the proximate cause of her broken shoulder.

Cases

Smithers v. Atlantic City Railroad, 12 Nowhere 2d 5 (2021)

Mr. John Smith was injured on the Atlantic City Railroad when the train lurched with great violence as it rounded a curve on the track. The train was overcrowded. Smith was injured without fault on his part. The motorman drove the overcrowded car too fast around the curve, so as to cause it to give a severe lurch. Where a passenger train is overcrowded and the employees operating the train know of such condition, it is their duty to exercise additional care commensurate with the dangers. The motorman knew of the overcrowded conditions and failed to exercise additional care when rounding the curve. Mr. Smith was injured when the train lurched as it rounded the curve because he fell onto another passenger. The motorman's failure to exercise the requisite care was the proximate cause of Mr. Smith's injuries.

Blue v. Boardwalk Railroad, 15 Nowhere 2d 9 (2020)

Mr. Robert Blue was blinded by a sudden gust of steam and fell underneath the train he was in the process of boarding at the station. Mr. Blue's arm was severed by the train as it started to leave the station. Regular inspection of couplings is a required duty of conductors. Failure to inspect the couplings for leaks is a negligent act on the part of the defendant. Railroad's allowing steam to escape was the proximate cause of Mr. Blue's injury, since a man of ordinary prudence could have foreseen that escaping steam would result from leaks in the uninspected couplings. The consequence of the escaping steam, due to the railroad's failure to inspect the couplings, resulted in a foreseeable injury to a passenger or person waiting on the platform.