Others on Noonan on Paslgraf

It's true that Judge Noonan did us all a great jurisprudential favor by telling the story of Helen Palsgraf.  I'm not sure it's quite true, though, that Judge Noonan regarded Judge Cardozo as "mechanically following [the] rule," as has been represented  here.  After all, as Noonan also reports, the statute was in desuetude, unenforced for many years.  Cardozo's following it, therefore, especially given all else we know and admire about Cardozo, can't likely have been merely "mechanical[]."