## Facts

- L. E. Haney, a railroad switchtender in Memphis, worked with switches and signals for trains using a station area with uneven ground and poor lighting.
- On a dark night, Haney set a switch to permit a backing train movement; when the expected signal change did not occur, coworkers found him near the tracks with a fatal head injury.
- The estate alleged Haney was struck by a protruding mail hook on a passing car, possibly while standing on mounds of dirt and cinders near the track.
- The railroads argued the death was caused by an unknown assailant and that the mail-hook theory lacked evidentiary support.
- A jury returned a plaintiff’s verdict under the Federal Employers’ Liability Act (FELA).
- The state high court set aside the verdict and directed judgment for defendants, reasoning the plaintiff’s causation theory was speculative and the evidence of unsafe conditions was insufficient; it also rejected certain testimony as hearsay.
- The U.S. Supreme Court reviewed whether the case was improperly taken from the jury.

## Issues

1. Whether the evidence provided a sufficient evidentiary basis for a jury to find negligence and causation under FELA.
2. Whether an appellate court may set aside a FELA jury verdict by recharacterizing competing inferences as speculation when probative facts support the verdict.
3. Whether evidentiary rulings justified overturning the verdict where other evidence supported the jury’s finding.

## Decision

- The Supreme Court reversed the judgment that directed a verdict for defendants and reinstated the jury’s role in resolving the factual dispute.
- The Court held there was a reasonable evidentiary basis for the jury to infer that railroad negligence contributed to Haney’s death.
- The Court rejected the appellate court’s approach of weighing competing inferences and substituting its judgment for the jury’s where probative facts supported the verdict.
- The Court indicated that evidentiary rulings are generally committed to the trial judge’s discretion and, in any event, the verdict was supported by evidence independent of the challenged testimony.

## Legal Principles

- In FELA cases, appellate review is limited: a jury verdict must stand unless there is a complete absence of probative facts supporting the jury’s conclusion.
- An appellate court may not weigh conflicting evidence, assess witness credibility, or choose among reasonable inferences to reach a contrary result.
- Circumstantial evidence may support a negligence and causation finding, and the presence of an alternative explanation does not permit overturning the verdict if the jury had a rational basis for its choice.
- Trial-level evidentiary rulings are ordinarily reviewed deferentially and do not warrant setting aside a verdict supported by other admissible evidence.

## Conclusion

The Court held that the jury’s FELA verdict could not be displaced because the record contained probative facts supporting a reasonable inference of railroad negligence contributing to the employee’s death, and appellate courts may not reweigh evidence or reject the jury’s permissible inferences.


Lavender v. Kurn, 327 U.S. 645 (1946)