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Galloway v. United States

Citation. 319 U.S. 372 (1943)
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Brief Fact Summary.

Plaintiff’s wife bringing suit to get total disability for her veteran husband. Plaintiffs lose in trial court after the court accepts Defendant’s motion for a directed verdict, which Plaintiff challenges.

Synopsis of Rule of Law.

A directed verdict does not violate the Seventh Amendment.


Plaintiff Galloway served in the military from 1917-1922 and claimed to have psychological problems from his time serving in France in 1918. Years later he applied for total disability but was denied. Plaintiff’s wife brought suit. At the close of evidence during trial, the district court granted Defendant United States’ motion for a directed verdict. The court of appeals affirmed and the United States Supreme Court granted certiorari.


Does a directed verdict violate the Seventh Amendment?


No, a directed verdict does not violate the Seventh Amendment. The holding below is affirmed.


Justice Justice Black with Justices Douglas and Murphy dissenting

A motion for a directed verdict should only be granted when there is no evidence of a genuine dispute of material fact. It is not the role of the court to make determinations based on credibility of witnesses as the court did here. That is for the jury to decide. There is substantial evidence that Plaintiff may actually suffer from a total and permanent mental disability and he should be allowed to present other evidence relating to his mental status at a new trial.


  1. History does not support requiring all causes of action to be heard by a jury.
  2. The Seventh Amendment is intended to protect a jury trial’s most fundamental elements, not to allow parties to proceed to trial.
  3. Plaintiff Galloway has not met his burden of proving that he continues to experience his disability.
  4. The evidence Plaintiff Galloway presented does not show that his mental disability is total and permanent.
  5. The trial court was correct in granting Defendant’s motion for a directed verdict.
  6. The holding below is affirmed.

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