Weisgram v. Marley Co. case brief

Weisgram v. Marley Co. case brief summary
528 U.S. 440 (2000)

CASE SYNOPSIS

On writ of certiorari to the United States Court of Appeals for the Eighth Circuit, petitioner appealed the judgment of the appellate court, which held that the expert evidence was incompetent to prove petitioner's wrongful death case and directed entry of judgment for respondent.

CASE FACTS
Petitioner brought a diversity action seeking wrongful death damages. The district court denied respondent's motions for judgment as a matter of law and entered judgment for petitioner. The appellate court directed entry of judgment for respondent.

DISCUSSION

• Courts of appeals were divided on whether Fed. R. Civ. P. 50 permitted an appellate court to direct the entry of judgment as a matter of law when it determined that evidence was erroneously admitted and that the remaining evidence was insufficient. 
• The court found unconvincing petitioner's fears that allowing appellate courts to direct the entry of judgment for defendants would have punished plaintiffs who could have shored up their cases by other means had they known their expert testimony was inadmissible. 
• After holding petitioner's expert testimony inadmissible, the appellate court evaluated the evidence presented at trial, and found the properly admitted evidence insufficient to support the verdict. Petitioner offered no specific grounds for a new trial. 
• The appellate court did not abuse its discretion by directing entry of judgment for respondent, instead of returning the case to the district court for further proceedings.

CONCLUSION
Judgment affirmed; once the erroneously admitted testimony was removed, there remained insufficient evidence to support the jury's verdict, and the appellate court acted within its authority when it directed the entry of judgment as a matter of law.

Recommended Supplements for Civil Procedure