Franco v. Richland Refrigerated Solutions, LLC

Plaintiff filed a lawsuit for personal injuries in federal court pursuant to diversity jurisdiction. Defendant admitted that the negligence of its employee caused an automobile collision but denied that it was the cause of plaintiff’s injuries. The jury entered a verdict in favor of the defendant and plaintiff appealed the district court’s pre-trial rulings, jury instructions, and denial of plaintiff’s post-trial motion. The Seventh Circuit affirmed, finding the district court did not err in denying plaintiff’s motions for judgment as a matter of law because a reasonable jury could find the accident did not cause plaintiff’s injuries, that the district court did not abuse its discretion in denying plaintiff’s request for a new trial because the jury’s verdict was not against the manifest weight of the evidence, that the district court’s instruction and explanation of causation accurately stated the law, and that the trial court did not abuse its discretion when it allowed some, but not all, of plaintiff’s demonstrative exhibits. (SYKES, concurring)