The Andrews test is broader than the Cardozo test.

Name: The Andrews test is broader than the Cardozo test.
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The Andrews test, stemming from the Palsgraf v. Long Island Railroad Co. case, establishes a broader criterion for duty of care, suggesting that a duty is owed to anyone who could be foreseeably harmed by one's actions. In contrast, the Cardozo test, also from the Palsgraf case but focusing on Justice Cardozo's opinion, is narrower, suggesting a duty only to those within a "zone of danger."

The Andrews Test Is Broader Than the Cardozo Test