Dekalb-Cherokee Counties Gas District v. Timothy Raughton

Summary

The Alabama Supreme Court reversed the trial court’s denial of DeKalb‑Cherokee Counties Gas District’s renewed motion for judgment as a matter of law, holding that there was no substantial evidence of negligence by the employee’s clutch‑release maneuver or by the district’s failure to inspect the dump‑truck, and that the appropriate standard of review for a JML motion is the substantial‑evidence test. The Court affirmed that questions of law are reviewed de novo. The decision notes that the result would be the same regardless of the specific duty analysis applied.