Breayonna Aaron, Individually and on Behalf of Richie Terrell Aaron, Jr., Deceased, and Her Minor Children, M. A., R. A. and L. A., et al. v. National Railroad Passenger Corporation, dba Amtrak

Under Federal Rule of Civil Procedure 50, a court may grant judgment as a matter of law where there is no “legally sufficient evidentiary basis to find for the party on that issue.” But Rule 50 does not specify what is “legally sufficient.” Both the States and the lower federal courts have developed their own distinct standards for determining legal sufficiency. And, as this Court has recognized, federal courts are split over whether state or federal law governs legal sufficiency on state-law claims in federal court. Petitioner Breayonna Aaron, individually and on behalf of her children, sued Amtrak under Missouri law for negligence and the wrongful death of her husband, Richie Terrell Aaron, Jr., following his tragic shooting on an Amtrak train. After a trial, a jury found for Mrs. Aaron, and the district court denied Amtrak’s motions for judgment as a matter of law. The Eighth Circuit reversed. Despite Mrs. Aaron’s urging, the court refused to apply Missouri’s legal sufficiency standard, which requires that a jury’s verdict be respected unless there is a “complete absence of probative facts” to support it. Instead, the court undertook its own qualitative assessment of the evidence and set aside the verdict. The questions presented are:

1. Whether state or federal law governs the standard for the legal sufficiency of the evidence underlying a motion for judgment as a matter of law as to a state-law claim in federal court.

2. If federal law governs this determination, whether a court may decide legal sufficiency based on its own qualitative assessment that reweighs, or selectively considers, the evidence heard by the jury.