Galloway v. United States

Brief Fact Summary.

The Petitioner, Galloway (Petitioner), claimed that his mental insanity was caused by his involvement in the military and sued the Government. The District Court granted the Government’s motion for a directed verdict and held for the Government, citing Petitioner’s lack of sufficient evidence to prove his claim. Petitioner appealed, stating that his Seventh Amendment of the United States Constitution (Constitution) right to a jury trial was denied because of the directed verdict.

Synopsis of Rule of Law.

Directed verdicts do not deprive litigants of their Seventh Amendment constitutional right to a jury trial.

Facts.

Petitioner was a longshoreman before enlisting in the Army in 1917. From that point until 1922, Petitioner had an on and off history with the Army and Navy. In 1930 he began a series of medical examinations with the Veterans’ Bureau which labeled him as having psychosis. Petitioner claimed that he was now totally and permanently disabled by reason of insanity brought about by the strain of active service abroad. Petitioner alleged that his insanity had existed before May 31, 1919, the day on which his yearly renewable term insurance policy lapsed for nonpayment of the premium. To prove his case, Petitioner offered a series of six witnesses who knew him before and after service and would comment on his behavioral change. The Petitioner’s burden was to demonstrate by more than speculative inference that this condition began on or before May 31, 1919 and continuously existed or progressed until 1930. The Government motioned for a directed verdict and the District Court gra
nted it in favor of the Government stating Petitioner did not meet his burden with the evidence he presented. Petitioner claimed the directed verdict denied him his right to a jury trial. The Court of Appeals affirmed the District Court’s ruling.

Issue.

Whether a directed verdict denied Petitioner the right to a jury trial.

Held.

No. History and precedent support the conclusion that the Seventh Amendment of the Constitution was designed to preserve a jury trial in instances of the most fundamental elements. Here, speculation could not substitute for probative facts. It was the Petitioner’s burden to show by nature of the claim that he suffered from continuing and total disability for nearly twenty years. His inability to show the continuing disability, as per the statute, left his claim vague and incomplete and therefore, properly subjected to a directed verdict. Affirmed.

Dissent.

United States Supreme Court Justices Hugo Black (J. Black), William Douglas (J. Douglas), and Frank Murphy (J. Murphy) dissented and argued that directed verdicts should only be used, if at all, when without weighing the credibility of the witnesses, there is no room in the evidence for honest difference of opinion over the factual issue in controversy. Further, the majority’s chief reason for approving the directed verdict was that no evidence except medical testimony was offered for a five to eight year period. The Court should at least authorize a new trial because Petitioner’s knowledge that his evidence did not satisfy a judge, but perhaps could satisfy a jury, could make him obtain more evidence to fill that time period.

Discussion.

The Petitioner’s burden was to show, according to the statute, that he was totally and completely insane from on or before May 31, 1919 through 1930. The Court held that the evidence Petitioner brought forth was speculative and vague. At best, the Petitioner produced evidence of specific episodes during that time, but could not prove his continuous disability. The Court further noted that the Petitioner wanted the Court to infer his insanity for the whole time period stated and that inference did not take the place of evidence. Therefore, Petitioner’s burden was not met.
The Court reasoned that the Seventh Amendment of the United States Constitution (Constitution) had no application in this case to begin with because it was for a monetary claim against the Government, which historically did not go to a jury. Further, and more importantly, the directed verdict practice was valid because of prior precedent and its presence in the Federal Rules of Civil Procedure (FRCP).