## Facts

- A brakeman, Frederick Chamberlain, died during switching operations in a large freight yard using a lead track over a hump and gravity-fed strings of cars.
- Chamberlain rode a two-car string moving onto track 14; a seven-car string was ahead on the same track, and a nine-car string followed.
- Chamberlain’s body was later found on track 14 beyond the switch, indicating he fell and was run over.
- The estate sued under the Federal Employers’ Liability Act, alleging negligent switching caused a violent contact that threw Chamberlain from the cars.
- The plaintiff’s theory depended on a collision between the nine-car string and Chamberlain’s two-car string.
- Multiple railroad employees riding or observing the nine-car string testified directly that no collision occurred, and that the nine-car string did not contribute to the accident.
- The plaintiff’s key witness, located about 50 feet from the track and far from where the body was found, heard an unusually loud crash (not uncommon in the yard), later saw cars moving together, and inferred a collision caused the crash.
- No witness observed Chamberlain’s fall or identified a specific negligent act causing it; the asserted collision was an inferential explanation among other plausible causes.

## Issues

1. Whether a FELA wrongful-death plaintiff may reach the jury when the evidence permits two equally reasonable but inconsistent inferences about causation, only one of which attributes the injury to the defendant’s negligence.
2. Whether a directed verdict is proper where the plaintiff’s case rests on an inference that is equally consistent with a non-negligent cause and is opposed by positive, unimpeached testimony.

## Decision

- The Supreme Court reversed the court of appeals and reinstated the district court’s directed verdict for the railroad.
- The Court held the evidence was legally insufficient to support a finding that Chamberlain’s death resulted from a collision caused by the railroad’s negligence.
- The circumstances supported competing inferences that were equally consistent with negligence and non-negligence, so the plaintiff failed to carry the burden of proof.
- The plaintiff’s witness’s statement attributing the crash to a collision was treated as a conclusion based on inference, not an observed fact capable of overcoming the evidentiary deficit.
- An inference of collision was not permissible against uncontradicted, unimpeached testimony affirmatively denying any collision and consistent with the established circumstances.

## Legal Principles

- A plaintiff cannot recover by proving facts that support an inference of negligence when the same facts give equal support to an inconsistent inference not attributable to the defendant.
- When proven facts equally support two inconsistent inferences on a vital element, neither inference is established; judgment must go against the party bearing the burden to prove one over the other.
- A witness’s conclusory attribution of cause cannot resolve evidentiary equipoise where the underlying facts support opposing inferences equally.
- An inference necessary for recovery cannot stand against positive, otherwise uncontradicted and unimpeached testimony, consistent with the proved facts, showing the inferred fact did not occur.
- A directed verdict is proper when the evidence for an essential element is so insubstantial that an adverse verdict would not be sustainable as a matter of law.

## Conclusion

The Court held that the estate’s circumstantial proof left causation in equipoise between negligent and non-negligent explanations and could not overcome direct testimony denying a collision; because negligence was not shown to be more probable than non-negligence, the railroad was entitled to a directed verdict.


Pennsylvania R. Co. v. Chamberlain, 288 U.S. 333 (1933)