## Facts

- Richard P. Wratchford was severely injured on a Maryland highway reconstruction site and was found at the bottom of an open drainage structure (catch basin/manhole) near the traveled way.
- The work involved a general contractor (S.J. Groves & Sons Co.) and a subcontractor (Dale W. Miller).
- Plaintiffs (Wratchford’s conservators) alleged defendants negligently failed to protect the opening with a cover, grate, barricade, or adequate warnings.
- Wratchford was last seen the prior evening walking in the general direction of his home; he could not explain how the incident occurred.
- Defendants argued the injuries could have resulted from slipping on ice near the opening and then falling in, making causation not attributable to defendants’ negligence.
- Defendants also asserted defenses based on contributory negligence and the State’s acceptance of the road work.

## Issues

1. In a federal diversity action, does state law or federal law govern the standard for deciding whether evidence is sufficient to submit the case to the jury (or to direct a verdict)?
2. Under the proper standard, was the circumstantial evidence on causation and negligence sufficient to require jury determination rather than a directed verdict for defendants?

## Decision

- The Fourth Circuit held the federal standard governs the sufficiency of evidence for jury submission in diversity cases.
- Applying the federal standard, the court concluded a reasonable jury could find defendants’ negligence more likely than not caused Wratchford’s injuries.
- The directed verdict for defendants was improper.
- Contributory negligence and the effect of the State’s acceptance of the work were treated as fact questions for the jury on this record.
- The judgment was reversed and remanded for further proceedings.

## Legal Principles

- In diversity cases, federal law controls the judge–jury allocation on motions testing evidentiary sufficiency (e.g., directed verdict/JNOV), even though state substantive law governs the underlying claim.
- A case supported by circumstantial evidence must be submitted to the jury if reasonable jurors could draw different inferences from the evidence.
- A court may not remove a case from the jury solely because the judge views competing inferences (liability and nonliability) as equally probable; resolving such inferential conflicts is for the jury.

## Conclusion

The Fourth Circuit required use of the federal sufficiency-of-the-evidence standard in diversity cases and held that plaintiffs’ circumstantial evidence permitted a reasonable jury to find causation and negligence, making a directed verdict for defendants improper.


Wratchford v. S.J. Groves & Sons Co., 405 F.2d 1061 (4th Cir. 1969)