Pennsylvania Railroad Co. v. Chamberlain

Brief Fact Summary.

Chamberlain filed a negligence action against Pennsylvania Railroad Co. seeking to recover damages for the death of a brakeman; Chamberlain’s case rested entirely on the claim that the brakeman’s death was caused by a violent collision of train cars. The trial court, at the conclusion of the evidence, directed the jury to find a verdict for Pennsylvania Railroad Co., finding that there was no evidence upon which the jury could properly proceed to find a verdict for Chamberlain.  The Court of Appeals reversed.

Synopsis of Rule of Law.

Where a plaintiff’s case is based on an inference (or inferences), the case fails upon proof of undisputed facts inconsistent with that inference(or inferences); before evidence may be left to the jury, it must be determined whether there is any evidence upon which a jury can properly proceed to find a verdict for the party producing the evidence, who has the burden of proof.

Facts.

Chamberlain sued Pennsylvania Railroad Co. for alleged negligence that resulted in the death of a brakeman. The complaint alleged that the brakeman was assisting in breaking up and making up trains, as well as classifying and assorting train cars, that other employees were riding in train cars that were negligently brought into contact with the car in which the brakeman was riding, and that, as a result of the contact, the brakeman sustained injuries that led to his death. Chamberlain’s case rested entirely on the claim that the brakeman’s death was caused by a violent collision of the train cars; one witness’s testimony inferred this view of the facts. Unimpeached testimony of additional witnesses was to the contrary. The trial court, at the conclusion of the evidence, directed the jury to find a verdict for Pennsylvania Railroad Co., finding that there was no evidence upon which the jury could properly proceed to find a verdict for Chamberlain.  The Court of Appeals reversed.

Issue.

Did the trial court err in directing the jury to find a verdict in favor of Pennsylvania Railroad Co.?

Held.

No. The Supreme Court reversed the Court of Appeal’s decision; the decision of the district court directing the jury to find a verdict in favor of Pennsylvania Railroad Co. was affirmed.

Discussion.

Where plaintiff’s case is based on an inference or inferences, the plaintiff’s case fails upon proof of undisputed facts inconsistent with those inferences. In this case, the witness’s testimony in support of Chamberlain’s case, which was based on an inference of a collision, was “suspicious, insubstantial, and insufficient,” and “incredible”; testimony of all other witnesses established that there was no collision. Other than the inference relied upon by Chamberlain, there was no substantial support in the evidence for Chamberlain’s case, and a verdict for Chamberlain would have rested upon mere speculation and conjecture.