Dick v. New York Life Insurance Company (1958)
- Docket
- 58
- Decided
- 1958-01-01
- Category
- General
Summary
Question: Did the Eighth Circuit United States Court of Appeals properly reverse the district court’s determination that the cause of William Dick’s death was a question of fact for the jury? Conclusion: No. In a 6-2 decision written by Chief Justice Earl Warren, the Court held that the Fourth Circuit erred in reversing the judgment of the district court. Chief Justice Warren argued that the jury could have determined that William Dick's death was accidental from the evidence Blanche Dick presented at trial, emphasizing that the evidence apparently did not suggest that William had either the motive or intention to commit suicide. He also noted that William was in the middle of his chores when he died, which the jury could have reasonably concluded to be improbable timing for a suicide attempt. Chief Justice Warren declined to answer whether a state or federal evidentiary standard is proper when jurisdiction is based on the diversity of the parties because both parties assumed the North Dakota standard was proper in their briefs and arguments. Justice Potter Stewart concurred, agreeing that the district court properly applied North Dakota’s evidentiary standard. Justice Stewart noted that he was not a member of the court when the case was granted a writ of certiorari, and thus refrained from expressing an opinion on whether the Court granted the writ appropriately. Justice Felix Frankfurter, joined by Justice Charles Whittaker, dissented. He argued that the Court improperly granted a writ of certiorari to Blanche Dick’s case. Justice Frankfurter outlined the history of diversity jurisdiction cases in the circuit courts, emphasizing that congress intended the Court to use its certiorari power sparingly in such cases. He argued that the Eighth Circuit properly applied North Dakota’s evidentiary standard and concluded that Blanche's claim fell short of the North Dakota requirements for submission to a jury. Justice John Harlan took no part in the consideration or decision of the case.