Galloway v. United States

Citation. 319 U.S. 372 (1943)

Brief Fact Summary.

Petitioner sued Respondent for not granting his disability application. Respondent filed a motion for directed verdict.

Synopsis of Rule of Law.

A directed verdict does not violate a party’s rights under the Seventh Amendment.

Facts.

Joseph Galloway (Petitioner), a veteran, applied for disability benefits from the Veterans Administration on theory that service in France caused him to have a mental breakdown leading to insanity. The application was denied, and Petitioner sued the U.S. government (Respondent). Respondent filed a motion for a directed verdict.

Issue.

Based on the evidence, did the District Court properly grant the motion for a directed verdict?

Held.

Yes, the District Court properly granted the Respondent’s motion for a directed verdict.

Dissent.

Justice Black

Justice Black argued that Petitioner did provide sufficient evidence of total disability. Furthermore, Justice Black argued that a directed verdict should only be used when there could be no difference of opinion on the factual issues of the case.

Discussion.

The Court determined that the evidence presented linking Petitioner’s insanity to his time spent in France was speculative. The District Court properly granted the Respondent’s motion for a directed verdict because Petitioner failed to meet his burden of showing a continuous total disability over the eight year period. Furthermore, the Court determined that granting the motion for a directed verdict did not violate Petitioner’s rights under the Seventh Amendment because the lawsuit was for a monetary claim against the United States. The Court noted the motion for a directed verdict was also supported by precedent and the Federal Rules of Civil Procedure.