Spurlin v. General Motors Corp.

Brief Fact Summary.

Plaintiffs, through their parents, sued Defendant for negligently designing the braking system and improperly instructing owners of the school bus, in which two of Plaintiffs died and twenty-two were injured, as to how frequently the braking system should be serviced. The jury found for Plaintiffs. The trial court granted Defendant’s motion for judgment notwithstanding the verdict and motion for new trial. Plaintiffs appealed. 

Synopsis of Rule of Law.

If there is sufficient evidence to allow reasonable people to differ as to the proper verdict to render in a given case, the matter will be submitted to the jury and a judgment notwithstanding the verdict is improper.

Facts.

In April 1968, a school bus manufactured by General Motors (Defendant) and owned by Morgan County, Alabama crashed, killing two children and injuring twenty-two. The crash was caused by a failure of the bus’ brakes. All of the children on the bus (Plaintiffs), through their parents, sued Defendant for negligently designing the braking system as well as improperly instructing owners of the bus as to how frequently the braking system should be serviced. The case was tried in front of a jury and the jury found for Plaintiffs. Defendant moved for a judgment notwithstanding the verdict or, in the alternative, for a new trial. The trial court granted both motions. Plaintiffs appealed.

Issue.

Whether judgment notwithstanding the verdict is appropriate when the evidence produced at trial would lead reasonable people to differ as to the proper verdict.

Held.

No. The trial court’s ruling is reversed. If there is sufficient evidence to allow reasonable people to differ as to the proper verdict to render in a given case, the matter will be submitted to the jury and a judgment notwithstanding the verdict is improper.

Discussion.

The jury’s role is to weigh the evidence in a given case in order to come to a determination as to the proper outcome. This weighing of the importance of the evidence, even if the specific facts of the case are not in dispute, is one of the fundamental roles of the jury. Therefore, any verdict that requires the weighing of facts is one that requires that a jury issue the final verdict and not the judge. This was the case here. Both parties presented expert testimony regarding the braking system on the school bus and whether it was deficient. The jury was charged with deciding whether or not any problems with the braking system rose to the level of negligence, a charge that juries must often carry out. The fact that the weighing of expert testimony and technical evidence was carried out by the jury indicates that this case was not one where a judgment notwithstanding the verdict was proper.