Friday, December 27, 2013

Grunenthal v. Long Island Rail Road case brief

Grunenthal v. Long Island Rail Road case brief summary
393 U.S. 156 (1968)

Petitioner, former employee, was granted certiorari to review the judgment of the United States Court of Appeals for the Second Circuit, which ordered the district court to grant respondent railroad a new trial in the employee's action under the Federal Employers' Liability Act (FELA), 35 Stat. 65, 45 U.S.C.S. § 51 et seq.(amended), unless the employee agreed to a remittitur of part of the award in his favor.

The employee was working on a track gang when a 300-pound railroad tie fell and severely crushed his right foot, permanently disabling him from work. The appellate court ruled that the trial court abused its discretion in denying the railroad's motion.


  • Upon review, the court reversed the appellate court's judgment, noting that the appellate court did not make a detailed review of the evidence in support of the jury's verdict. 
  • The court's independent review of the evidence led it to conclude that the trial court's judgment should not have been disturbed. 
  • The trial judge's opinion showed that he reviewed the factors on which the jury based its opinion, and, applying that standard, found that the relevant evidence weighed heavily in favor of the jury's assessment. 
  • The jury instructions limited the items of damages to wages lost before trial, compensation for loss of future earnings, and past and continuing pain and suffering. 
  • The court concluded that the trial judge did not abuse his discretion in finding nothing untoward, inordinate, unreasonable or outrageous in the jury's verdict.
The court reversed the appellate court's judgment and remanded the case with direction to enter a judgment affirming the district court's judgment.

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