Case Citation
Legal Case Name

LAVENDER v. KURN Case Brief

Supreme Court of United States1946
327 U.S. 645 66 S.Ct. 740 90 L.Ed. 916

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Case Brief Summary & Legal Analysis

General Brief
3 min read

tl;dr: A railroad worker was killed, with competing theories of accidental death by a train hook or murder. The Supreme Court held that a jury verdict based on circumstantial evidence must stand if there is any evidentiary basis, even if other conclusions seem more reasonable.

Legal Significance: Establishes an extremely deferential standard of appellate review for jury verdicts in FELA cases. An appellate court cannot reweigh evidence if there is any “evidentiary basis” for the jury’s conclusion, effectively protecting the jury’s right to draw reasonable inferences from circumstantial evidence.

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Case Facts & Court Holding

Key Facts & Case Background

L.E. Haney, a railroad switch-tender, was found unconscious near railroad tracks shortly after a train had backed past his position. He later died from a fractured skull. There were no eyewitnesses to the incident. The petitioner, Haney’s administrator, sued under the Federal Employers’ Liability Act (FELA), alleging negligence. Petitioner’s theory was that Haney was struck by a mail hook protruding from the side of the moving train. Evidence was presented that the hook could swing outward and, if Haney were standing on a nearby mound of dirt, could have struck him at the precise height of his injury. The respondent railroads countered with a theory that Haney was murdered by a transient, pointing to the dark, unsecured area and the later discovery of Haney’s empty wallet. The respondents also presented evidence suggesting it was physically impossible for the mail hook to have struck Haney. A jury returned a verdict for the petitioner. The Supreme Court of Missouri reversed, holding that the petitioner’s theory was “mere speculation and conjecture” and that there was no substantial evidence of negligence to support the verdict.

Court Holding & Legal Precedent

Issue: May an appellate court set aside a jury verdict in a FELA case by reweighing conflicting evidence and determining that the plaintiff’s theory of causation is based on speculation, even if there is some evidentiary basis for the jury’s conclusion?

No. The judgment of the Supreme Court of Missouri is reversed. A Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu

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IRAC Legal Analysis

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Legal Issue

May an appellate court set aside a jury verdict in a FELA case by reweighing conflicting evidence and determining that the plaintiff’s theory of causation is based on speculation, even if there is some evidentiary basis for the jury’s conclusion?

Conclusion

Lavender v. Kurn establishes a highly deferential standard for reviewing jury verdicts, Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea co

Legal Rule

An appellate court's function in reviewing a jury verdict is exhausted once Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Dui

Legal Analysis

The Supreme Court held that the Missouri Supreme Court improperly invaded the Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proi

Flash-to-Full Case Opinions

Flash Summary

  • A jury verdict in a Federal Employers’ Liability Act (FELA) case
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sin

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