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Under certain circumstances an appellate court may enquire into the action of the trial court on a motion for a new trial. Thus, its denial may be reviewed if the trial court erroneously excluded from consideration matters which were appropriate to a decision on the motion, or if it acted on the mistaken view that there was no jurisdiction to grant it, or that there was no authority to grant it on the ground advanced.
Plaintiff Cub Fork Coal Company and Paragon Colliery Company brought this action in the federal court to recover damages from defendant purchaser Fairmount Glass Works for breach of a contract to purchase tons of coal that was deliverable in twelve monthly instalments. From the time when defendant refused to accept further deliveries until the end of the 12 months, there was a serious decline in the market price of coal. Defendant then pleaded several defenses and also set up a counterclaim as damages for failure to make delivery as provided by the contract. The jury’s verdict awarded $ 1 to plaintiffs and based upon the market prices proven at trial, the court of appeals reversed said judgment awarding nominal damages to plaintiffs. The court of appeals likewise deemed that the district court's refusal to grant the plaintiffs' motion for new trial was a reversible error. Following the parties' failure to stipulate to a modified judgment, the court of appeals directed that a new trial be granted on the issue of the plaintiffs’ damages. Defendant sought review of a judgment of the circuit court of appeals reversing a judgment awarding nominal damages to plaintiffs for the defendant’s breach of a contract for the sale of coal.
Was the district court’s refusal to grant the motion for new trial a reversible error?
The Court reversed the judgment of the appellate court and affirmed the district court's judgment awarding nominal damages to plaintiff sellers. The court, in concluding that the verdict was not inconsistent on its face, held that the district court's refusal to grant a new trial was not reversible error. The Court reasoned that the jury might have found in favor of the defendant purchaser on certain contested issues of liability and that the award of nominal damages could be explained by the jury's wish to have costs taxed against the defendant.