Balt. & Carolina Line, Inc. v. Redman - 295 U.S. 654, 55 S. Ct. 890 (1935)

Rule:

At common law there was a well established practice of reserving questions of law arising during trials by jury and of taking verdicts subject to the ultimate ruling on the questions reserved; and under this practice the reservation carried with it authority to make such ultimate disposition of the case as might be made essential by the ruling under the reservation, such as non-suiting the plaintiff where he had obtained a verdict, entering a verdict or judgment for one party where the jury had given a verdict to the other, or making other essential adjustments. This practice was well established when U.S. Const. amend. VII was adopted, and therefore must be regarded as part of the common law rules to which resort must be had in testing and measuring the right of trial by jury as preserved and protected by U.S. Const. amend. VII.

Facts:

Plaintiff instituted the present action, alleging that he sustained personal injuries through the defendant’s negligence. At the conclusion of the evidence, the defendant moved for a dismissal of the complaint because the evidence was insufficient to support a verdict for the plaintiff, and also moved for a directed verdict in its favor on the same ground. The court reserved its decision on both motions, submitted the case to the jury subject to its opinion on the questions reserved, and received from the jury a verdict for the plaintiff. Thereafter the court held the evidence sufficient and the motions ill-grounded, and accordingly entered a judgment for the plaintiff on the verdict. The court of appeals held that the trial court erred in denying defendant's motion for a directed verdict, reversing the judgment with a direction for a new trial. The court of appeals asserted that it could not itself determine the issues of fact and direct a judgment for defendant, for that would cut off plaintiff's unwaived right to have the issues of fact determined by a jury.

Issue:

Was the direction for a judgment for the defendant an infraction of the Seventh Amendment?

Answer:

No.

Conclusion:

On certiorari, the court affirmed the judgment of the court of appeals, as modified. It held that, upon remand, there should have been a judgment of dismissal on the merits, for the court was confronted with a purely legal question. The court pointed out that the practice of entering judgment on a point of law reserved, without objection, was known to the common law, and did not violate U.S. Const. amend. VII.