## Facts

- A Morgan County, Alabama school bus using a chassis and hydraulic brake system manufactured by General Motors suffered brake failure, left the roadway, and crashed, killing two children and injuring twenty-two.
- Injured children and representatives of deceased children sued General Motors, alleging negligent design of the braking system and inadequate warnings/instructions for inspection and maintenance.
- Plaintiffs’ design theory focused on the use of a single-circuit hydraulic system and the asserted absence of an effective emergency/backup braking capability for foreseeable school-bus use.
- The case was tried to a six-person jury over roughly two weeks with competing expert testimony on brake design, failure mechanics, and maintenance adequacy.
- The district court submitted the case to the jury on negligent design; the jury returned verdicts for plaintiffs, including damages in the wrongful-death and personal-injury claims.

## Issues

1. Whether the evidence was legally insufficient such that the district court properly entered judgment notwithstanding the verdict (JNOV) for General Motors on negligent design and causation.
2. Whether the district court properly granted a new trial on the ground that the verdict was against the great weight of the evidence and/or because of evidentiary rulings.

## Decision

- The Fifth Circuit reversed the JNOV.
- Applying the Boeing standard, the court held there was substantial evidence from which reasonable and fair-minded jurors could reach different conclusions on negligent design and proximate cause.
- The Fifth Circuit also reversed the conditional new-trial order, holding the district court abused its discretion by effectively substituting its view of the evidence for the jury’s.
- The jury’s verdicts for plaintiffs were reinstated.
- On rehearing-related arguments, the court concluded that exclusion of certain prior administrative pleadings did not warrant JNOV or a new trial.

## Legal Principles

- On directed-verdict and JNOV motions, a court must consider all evidence, drawing reasonable inferences in favor of the non-movant; if substantial evidence exists such that reasonable and fair-minded jurors could differ, the motion must be denied.
- In ruling on JNOV, the judge may not weigh conflicting expert testimony, choose among competing inferences, or make credibility determinations; those functions belong to the jury.
- A district court may grant a new trial when a verdict is against the great weight of the evidence, but appellate courts will reverse for abuse of discretion when the trial court primarily reweighs evidence and displaces the jury’s fact-finding role.
- Causation disputes involving foreseeable maintenance practices and competing accounts of fault may present jury questions when evidence permits findings against the manufacturer despite alleged negligence by third parties.
- Prior inconsistent pleadings may be admissible as admissions under applicable state law principles, but exclusion of such materials does not automatically require setting aside a jury verdict absent prejudice sufficient to undermine the verdict.

## Conclusion

The Fifth Circuit held that substantial evidence supported the jury’s findings on negligent design and causation, making JNOV improper, and that the district court’s new-trial order improperly reweighed the evidence; it reinstated the plaintiffs’ verdicts.


Spurlin v. Gen. Motors Corp., 528 F.2d 612 (5th Cir. 1976)