The torts of negligence and battery figure heavily in defenses of the Palsgraf principle, but other torts sometimes make an appearance as well. Suppose a defendant builds a hideous fence on A’s land, without her consent, and thereby causes the value of neighboring land owned by B to drop; or that the defendant defrauds A of her life savings and thereby prevents A from financially supporting the indigent B; or that the defendant makes a defamatory statement regarding A and thereby causes A’s business partner, B, to lose out on lucrative business opportunities.239 In each case A has an action against the defendant — in trespass, deceit, and defamation, respectively — but B does not. According to scholars who defend the Palsgraf perspective, it is the Palsgraf principle that explains these kinds of asymmetries: A tort defendant must behave wrongfully toward the plaintiff, by mistreating her in the manner articulated by the relevant tort, in order for her to recover.240
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