Lavender v. Kurn

L.E. Haney, an Illinois Central employee whose job included throwing switches for trains passing through a station, including those of St. Louis-San Francisco Railway Company (Frisco) and Illinois Central (defendants), was found dead one dark night with a fractured skull after opening but failing to close a switch for a passing Frisco train; the administrator of his estate (plaintiff) argued Haney was struck by a mail hook hanging from the Frisco train, supported by evidence that uneven ground near the tracks would sometimes put a person's head in range of such a hook, while the defendants argued Haney had instead been murdered, presenting evidence a hook could not have caused his injury. The jury found for the administrator, but the Missouri Supreme Court reversed for insufficient evidentiary support, and the U.S. Supreme Court granted certiorari.