Pennsylvania Railroad v. Chamberlain

Brief Fact Summary.

Plaintiff – the administrator of the decedent’s estate – sued Defendant, claiming that the decedent fell from the train on which he was riding because of a collision caused by Defendant’s negligence. Plaintiff’s only witness testified that he heard a bump that was not loud enough for him to turn around. He testified that he did not actually see a collision. Three employees riding the nine-car string testified that no such collision occurred. The trial court directed the jury to find a verdict in favor of Defendant. This was reversed on appeal.

Synopsis of Rule of Law.

A defendant is entitled to a directed verdict in a case where the proven facts give equal support to each of two inconsistent inferences concerning a critical fact in the case, where the plaintiff has the burden of proof.

Facts.

Plaintiff sued Defendant alleging that Defendant negligently caused the death of a brakeman whose estate was being administrated by Plaintiff. Plaintiff claimed that employees of Defendant negligently caused a multicar collision, resulting in the brakeman being thrown from the car he was riding and run over by another car. Three witnesses testified that no collision occurred. Plaintiff’s witness testified that there was a collision. The witness did not personally observe the collision, but merely inferred from the circumstances that the crash occurred. The trial court directed the jury to find in favor of Defendant, and the court of appeals reversed. The United States Supreme Court granted certiorari.

Issue.

Is a defendant entitled to a directed verdict in a case where the proven facts give equal support to each of two inconsistent inferences concerning a critical fact in the case, where the plaintiff has the burden of proof?

Held.

Yes. The Supreme Court reversed the judgment of the circuit court of appeals and affirmed the judgment of the district court, holding that district court properly directed a verdict in favor of the company on the state of the evidence before it.

Discussion.

A defendant is entitled to a directed verdict in a case where the proven facts give equal support to each of two inconsistent inferences concerning a critical fact in the case, where the plaintiff has the burden of proof. A party does not meet its burden of proof when it offers evidence that tends equally to sustain two inconsistent propositions. When a party fails to satisfy the burden of proof regarding a critical fact and a jury can draw two opposing, equally justifiable inferences from the facts (one for each party), a witness’ conclusion as to which inference should be drawn does not resolve the doubt in the party’s favor. Therefore, if the plaintiff’s evidence allows for two equal inferences that are inconsistent concerning a critical fact, the court should grant a directed verdict for the defendant. Here, Plaintiff’s witness testified that the collision occurred even though the witness did not personally observe the collision. The witness’s factual testimony was consistent with both a collision and a non-collision. Because this was the only testimony that supports a judgment in favor of Plaintiff, Plaintiff failed to satisfy her burden of proof.