The Palsgraf perspective struggles with all of these doctrines because none of them involve the defendant engaging in wrongful behavior toward anyone, let alone the plaintiff. In response, defenders of the Palsgraf perspective reject the legitimacy of these doctrines (and the powerful moral instincts embedded in them);265 or relegate them to the interpretive margins of tort law;266 or rely on metaphysical claims, such as the claim that an employer acts through the employee for whom it is vicariously liable,267 that are legal fictions (and thus call for a substantive normative rationale that the defenders of the Palsgraf perspective do not then supply268); or appeal to the claim that (some of) these defendants are committing legal wrongs, which is a formal observation that does not address the substantive objection that these putative legal wrongs are not tracking moral wrongs.269
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