Lavender v. Kurn
327 U.S. 645, 66 S. Ct. 740, 90 L. Ed. 916 (1946)
Haney, a switch operator for
train company, was found dead on the railroad tracks. The cause of death
was in doubt:
His estate (represented by
Lavender) argued that he was hit by a mail hook protruding from one of
the mail cars.
The railroad countered that
it would have been difficult for Haney to have been in a position to get
hit by a mail hook.
The railroad (represented by
Kern) argued that he was murdered by a hobo, as his wallet was found
several feet away from him with no money in it.
Haney's wife countered that
he didn't have any money.
The Trial Court found for
Lavender and awarded Haney's estate $30k. Kurn appealed.
The Missouri Supreme Court
reversed. Lavender appealed.
The Missouri Supreme Court
found that there was no substantial evidence of negligence to support the
submission of the case to a jury.
Basically, they were saying
that Kern should have won on summary judgment since there was insufficient evidence.
The US Supreme Court reversed
the Missouri Supreme Court.
The US Supreme Court found
that there was sufficient evidence of negligence for the Trial Court to
submit the case to the jury, and Appellate Courts should abide by such a
decision.
The Court found
that all a court needs is sufficient evidence to make a decision one way
or the other.
The Court felt
that the Appellate Courts had weighed the evidence, which is not
something Appellate Courts are empowered to do. It's not up to the
Appellate Courts to determine what is reasonable evidence and what is not.
Kern had argued that the
jury's verdict involved speculation and conjecture. But the
Court felt that all jury decisions involve some speculation and
conjecture. In fact, that's why you have a jury in the first place!
Basically, reversal is only
appropriate when there is a complete lack of probative facts to support a
conclusion. As long as there is some basis for the jury's verdict, the
jury is free to discard or disbelieve whatever facts are inconsistent with
its conclusion.
It is completely immaterial
that an Appellate Court might feel that the opposite conclusion is more reasonable.
Sometimes this is known as
the scintilla of evidence test,
meaning that, as long as there is one tiny piece of evidence to support a
jury's decision, that decision cannot be overruled by a higher court.