Presidio Components, Inc. v. American Technical Ceramics Corp.

Whether a court of appeals denies a prevailing party its right of trial by jury under the Seventh Amendment, when reversing the denial of a motion for judgment as a matter of law based on a classical fact issue without mentioning any evidence that supports the jury’s verdict or construing any evidence in the prevailing party’s favor, and making its own finding of fact for the first time on appeal? The Seventh Amendment of the U.S. Constitution mandates that the right of trial by jury shall be preserved, and no fact tried by a jury shall be otherwise reexamined in any Court of the United States. Those protections are abrogated if appellate courts do not strictly adhere to this Court’s well-established substantial evidence review of a fact tried to a jury, which occurs as to all of the evidence, and all of that evidence must be construed in the prevailing party’s favor. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150-151 (2000) (“[I]n entertaining a motion for judgment as a matter of law, the court should review all of the evidence in the record . . . [and] the court must draw all reasonable inferences in favor of the nonmoving party. . . .”). As such, a motion for judgment as a matter of law must be denied unless, upon review of all of the evidence, construed in the prevailing party’s favor, there is an absence of substantial evidence supporting a jury’s verdict. In this case, causation of lost profits was a classical fact tried to a jury, and therefore is protected by the