Minneapolis, St. Paul & Sault Ste. Marie Ry. Co. v. Moquin

Background

A worker sued an employer in a Minnesota county court to recover damages for injuries suffered while working in interstate commerce. The jury returned a verdict for the worker. The employer asked the trial court to set aside the verdict, saying the worker’s lawyer appealed to the jurors’ passion and prejudice and so prevented an impartial trial. The state supreme court found the verdict excessive because of those appeals, ordered a new trial unless the worker filed a remittitur (a written reduction of the award), and later affirmed judgment after a remittitur was filed.

Reasoning

The U.S. Supreme Court took up a narrow question: whether a verdict in a case under the federal employers’ liability law may stand if it was in any degree produced by appeals to passion or prejudice. The Court said it may not. The opinion explains that emotional appeals can produce not only excessive awards but wholly wrong verdicts. A party who wins a verdict through such tactics cannot keep the benefit by guessing how much of the award is unfair. Because the verdict was in any degree the result of improper appeals, the Court reversed the judgment.

Real world impact

The ruling requires that jury verdicts in cases brought under the federal employers’ liability law be free from improper emotional appeals. Where a verdict was affected by passion or prejudice, a remittitur cannot be treated as an adequate fix and a new trial may be required. The case was reversed and sent back for further proceedings consistent with this rule.