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Pennsylvania Railroad Co. v. Chamberlain

Supreme Court of the United States · 1933 · Civil Procedure

Civil Proceduredirected verdictsufficiency of the evidenceequal inferencesspeculation and conjecturescintilla rule rejectedburden of proofcircumstantial evidence

Facts

The deceased brakeman was riding a two-car string into track 14 in a switching yard, with a seven-car string ahead of him and a nine-car string behind him. Soon after his cars entered track 14, his body was found on that track beyond the switch, having fallen and been run over. Respondent's theory was that the nine-car string violently collided with the two-car string and threw him off. Every employee in a position to observe testified there was no such collision; respondent relied solely on Bainbridge, who heard a loud crash, later saw the two strings moving together, and inferred a collision although he had not been paying close attention and was about 900 feet away at an acute angle of vision.

Issue

Whether the evidence was sufficient to permit a jury to find that the nine-car string collided with the deceased's two-car string and caused his death. More specifically, whether a case may go to the jury when plaintiff's proof depends on an inference that is equally supported by an inconsistent inference and is contradicted by positive, unimpeached testimony.

Rule

When proven facts give equal support to each of two inconsistent inferences, neither inference is established, and judgment as a matter of law must go against the party who must sustain one of them to recover. In federal courts, evidence may go to the jury only if there is evidence upon which a jury can properly find for the party bearing the burden of proof; if the evidence is so insubstantial that a verdict would rest on mere speculation or conjecture, or is overwhelmingly one-sided, the judge should direct a verdict.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Chicago, Elena Ruiz sues Midlake Freight Systems for negligence after her husband, a dockworker, was found injured beside a loading lane. Her only proof that a company forklift struck him is testimony from Owen Price, who was 700 feet away, heard a metallic bang in a busy warehouse, and later saw a forklift and a pallet jack moving in the same corridor; the noise could just as easily have come from several other active loading bays.

If Midlake moves for judgment as a matter of law at the close of the evidence, how should the court rule?

Explanation. The motion should be granted. Under the majority's rule, when proven facts give equal support to two inconsistent inferences, neither is established. If the plaintiff bears the burden of proving one inference to recover, the case cannot go to the jury when the evidence leaves the matter to speculation and conjecture. Owen did not directly perceive the collision, and the bang was equally consistent with other activity in the warehouse.