Lavender v. Kurn

Citation. 327 U.S. 645 (1946)

Brief Fact Summary.

Petitioner sued Respondents for negligence after their employee, Haney, died on the job from being hit in the back of the head.

Synopsis of Rule of Law.

When a jury has rendered a verdict, based on reasonable inferences of the evidence submitted, the facts may not be disputed by a reviewing court.

Facts.

The administrator of the estate of L.E. Haney (Petitioner) sued trustees of the St. Louis-San Francisco Railway Company and Illinois Central Railroad Company (Respondents) for negligence following Haney’s death. Haney, a former switchman, was found dead on the job from an injury to the back of the head. Petitioner presented evidence that Haney was hit in the head by a mail hook negligently hanging from a passing train, and that the unlit and uneven ground negligently contributed to this dangerous workplace. Respondents presented evidence that Haney was murdered by an unknown assailant.

Issue.

Was sufficient evidence presented for the jury to reasonable infer that Respondents had acted negligently?

Held.

Yes, sufficient evidence was presented for the jury to make a reasonable inference in favor of the Petitioner. The lower court’s decision is reversed and remanded.

Discussion.

The Court determined that there for sufficient evidence of negligence regarding both whether Haney was struck in the head with the mail hook and whether the workplace was unsafe and dangerous for the jury to hear the case. Any additional evidence to the contrary became irrelevant after the jury made reasonable inferences based on the evidence and rendered a verdict, and thus could not be relitigated on appeal.