Fairmount Glass Works v. Cub Fork Coal Co.
United States Supreme Court
287 U.S. 474 (1933)
Cub Fork Coal Co. (plaintiff) sued Fairmount Glass Works (defendant) for breach of a coal supply contract, seeking over $32,000 in damages. After two prior trials were each reversed for legal errors, a third jury was properly instructed to award the difference between the contract price and market value if Fairmont breached — yet it returned a verdict for the plaintiff of just $1 in damages. Fairmont's motion for a new trial was denied by the trial judge. The court of appeals reversed, holding the damages award was inadequate as a matter of law and that at least $18,250 should have been recoverable; the Supreme Court granted certiorari.
Whether an appellate court may reverse a trial court's refusal to grant a new trial on the ground that the jury's damages award was too low, where the jury was properly instructed on how to calculate damages.