Pennsylvania Railroad v. Chamberlain (1933) [CB 594]
Facts: Action was brought alleging that Df's negligence caused the death of a brakeman. ○ Pl alleges that the death resulted from a violent collision of a string of railroad cars causing the brakeman to be run over. § Pl case is based on a testimony of a single employee, who said that at one point he saw the car on which the decedent was riding slowing down and other cars behind it gaining speed. Later he heard a loud noise, like a crash, but did not look. § Three other employees testified that no collision occurred. ○ The trial court directed a verdict for defendant. The appellate court reversed finding there was conflicting evidence and so a jury issue was present. Issue: Does a party sustain her burden of proof where the proven facts give equal support to two inconsistent inferences? -No Holding: reversed appellate court decision.
Reasoning: ○ As a rule, where there is a question of fact, the trier must determine it. § But here no conflict in the testimony as to the facts. □ The witness did not testify that an actual collision took place, but that he inferred it b/c he heard a crash. § They said that the circumstantial evidence (based on the inference) was so insubstantial and insufficient that it did not justify submission to the jury. § Since there's an inference as to what happened from both sides (no one actually saw what happened), then judgment as a matter of law must go against the person with the burden of production. § Court was also doubtful of witness' testimony. RULE: In a case where the proven facts give equal support to two inconsistent inferences, judgment must go against the party upon whom the burden of proof rests. Notes • Chamberlain case ○ As a matter of law, P not entitled to have a jury • How to prevent a manifest injustice without calling the 1st jury insane? Saying as a matter of law they could not believe bainbridge.