Lind v. Schenley Industries

Brief Fact Summary.

Plaintiff sued Defendant for alleged breach of an oral promise for an increase in pay. Plaintiff sought review of the the district court’s judgment for Defendant after a jury found that Plaintiff was entitled to compensation and moving expenses.

Synopsis of Rule of Law.

1. A trial judge may not set aside the jury verdict as contrary to the weight of the evidence if: 1) it is based solely on the fact that he would have come to a different conclusion and 2) no undesirable or pernicious element has actually occurred or been introduced into the trial. In other words, the judge must consider the character of the evidence, the complexity of the legal principles/case, and abstain from interfering with the verdict unless it is clear that the jury has reached a seriously erroneous result.
2. The reversal of a trial court’s granting of a motion for a new trial is reversible if the trial court failed to apply the proper legal standards in granting the motion.

Facts.

Plaintiff sued Defendant for alleged breach of an oral promise for an increase in pay. Both Plaintiff and his former secretary testified that the promise had been made. The jury returned a verdict for Plaintiff, and Defendant moved for judgment notwithstanding the verdict and, alternatively, a new trial. The trial judge granted the motion. Plaintiff appealed.

Issue.

1. What standard should a trial court apply in setting aside jury verdicts as being against the weight of the evidence?
2. What standard should an appellate court apply in reviewing new trial rulings.

Held.

No. The court reversed the district court’s decision, holding that the evidence was sufficient to support the jury’s verdict. The court also reversed the district court’s order of a new trial in the event that judgment in favor of Defendant was reversed.

Dissent.

Justice Hastie and Kalodner

The majority should not have questioned the trial judge’s conclusion that the verdict was against the weight of the evidence. There were facts in the record that made the verdict suspicious. First, it was very unlikely that the raise which Defendant allegedly promised to give Plaintiff would have more than quadrupled Plaintiff’s salary. Second, no such raises had ever been offered to similarly situated employees. Therefore, the trial judge’s decision was neither arbitrary nor abused his discretion. As a result, the trial judge’s decision should have been affirmed.

Discussion.

A judge may not set aside the jury verdict as contrary to the weight of the evidence based solely on the fact that he would have come to a different conclusion. A trial judge has wide discretion to grant a new trial and a new trial granted on the ground that the verdict is contrary to the weight of the evidence is generally non-reviewable. However, an appellate court may reverse the trial court’s judgment if there was a clear abuse of discretion whereby the trial court failed to apply correctly the proper legal standard. Where the case is simple and requires the jury only to weigh evidence that, if believed, presents an overwhelming case in the favor of one side and the trial judge nonetheless grants a new trial on the ground that the verdict was against the weight of the evidence, the trial judge essentially takes over the prime function of the jury as the trier of the facts and substitutes his judgment for that of the jury. Therefore, the appellate court must exercise a closer degree of scrutiny and supervision than is the case where a new trial is granted because of some undesirable or pernicious influence obtruding into the trial. Such a close scrutiny is required in order to protect the litigants’ right to jury trial.

Here, the case was a simple one that required the jury to weigh only the testimony of Plaintiff and his secretary, who, if believed, presented an overwhelming case in Plaintiff’s favor. If the jury chose to believe their testimony, the judge should respect that decision. Therefore, the court reversed the trial court’s judgment and reinstated the jury verdict.