Pennsylvania Railroad v. Chamberlain

Background

A family member (the person suing) brought this case against a railroad company to recover for the death of a brakeman who was working in a rail yard. The yard used a "hump" to sort cars; the deceased was riding two gondola cars toward track 14 when he was later found dead on that track. The plaintiff said a following nine-car string collided with the two-car string and threw the brakeman onto the track. At trial the judge directed a verdict for the railroad. The court of appeals reversed, but one judge dissented.

Reasoning

The Supreme Court examined whether the evidence could support the family's claim. The only witness supporting the collision theory was Bainbridge, who admitted he paid little attention, was about 900 feet away, saw at a sharp angle, and heard a loud crash; many employees who were in position to see testified there was no collision. The Court held that Bainbridge’s account was suspicious, contradicted by unimpeached witnesses, and at best created competing inferences. Where the facts equally support two inconsistent explanations, the court explained, a jury cannot be allowed to guess in favor of the plaintiff, so the trial judge properly withdrew the case from the jury.

Real world impact

The ruling means that when eyewitness evidence is weak, speculative, or contradicted by other direct testimony, judges may end the case for the defendant rather than send it to a jury. It limits recoveries in similar wrongful-death claims that rest on uncertain or circumstantial inferences.

Dissents or concurrances

A lower-court dissent argued the witness never clearly saw a collision and other witnesses' testimony made a verdict for the plaintiff unjustified; Justices Stone and Cardozo concurred in the result.