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

Rule:

On motions for directed verdict and for judgment notwithstanding the verdict a trial court should consider all of the evidence not just that evidence which supports the non-mover's case but in the light and with all reasonable inferences most favorable to the party opposed to the motion. If there is substantial evidence opposed to the motions, that is, evidence of such quality and weight that reasonable and fair-minded men in the exercise of impartial judgment might reach different conclusions, the motions shall be denied, and the case submitted to the jury. There must be a conflict on substantial evidence to create a jury question. However, it is the function of the jury as the traditional finder of the facts, and not the trial court, to weigh conflicting evidence and inferences, and determine the credibility of witnesses.

Facts:

Two wrongful death suits and twenty-two personal injury actions were filed by plaintiff surviving parents, on behalf of the children who were in the bus at the time, against the manufacturer of the school bus chassis, General Motors Corporation, when the bus's braking system failed and caused the bus to crash. Plaintiff received a favorable verdict but the lower court granted defendant's motion for judgment notwithstanding and, in the alternative, a new trial, on the ground that the verdict was not supported by the evidence. Plaintiffs appealed.

Issue:

Was the verdict in favor of plaintiffs unsupported by evidence, thereby justifying the grant of defendant’s motion for judgment notwithstanding verdict?

Answer:

No.

Conclusion:

On appeal, the court reversed the order of the lower court, holding that there was sufficient evidence for the jury to have found that the braking system was not reasonably safe and consequently that defendant breached its duty as a manufacturer because expert testimony indicated that the bus had a single hydraulic braking system when a dual hydraulic system was preferable and available within the industry and that the bus lacked an emergency brake. The court also held that there was ample evidence to submit the issue of proximate cause to the jury because there was conflicting evidence on the issue of the adequacy of the warnings in defendant's maintenance manuals for a jury to determine whether the county was negligent in failing to maintain the bus and whether such negligence was foreseeable by defendant.