New York courts continue to emphasize the deference owed to jury verdicts, particularly where credibility issues and competing inferences can be drawn from the evidence. A recent decision from the Appellate Division, Second Department in Krohn v Schultz Ford Lincoln, Inc.,2025 NY Slip Op 05072 (decided on September 24, 2025) illustrates this principle in the context of C.P.L.R. §4404(a) motions, negligence, and proximate cause, reversing a trial court’s order that set aside a jury verdict and directed judgment as a matter of law in favor of the plaintiff.

The plaintiff commenced a personal injury action alleging that the defendants negligently performed repair work on his van, causing a steering failure and a subsequent collision with a highway barrier. Following a bifurcated jury trial, the jury found that the defendants were negligent but that their negligence was not a substantial factor in causing the plaintiff’s alleged accident. The Supreme Court set aside that portion of the verdict pursuant to C.P.L.R. §4404(a), concluding that there was no valid line of reasoning by which the jury could have found negligence without proximate cause, and directed judgment for the plaintiff on liability. The defendants appealed.

The Second Department reversed, reiterating the distinction between a verdict that is legally insufficient and one that is merely against the weight of the evidence. The Court cautioned that these standards are frequently conflated but carry materially different consequences. A finding of legal insufficiency permits the court to replace the jury’s verdict with its own judgment, whereas a finding based on the weight of the evidence may only result in a new trial.

Applying the stringent insufficiency standard, the Appellate Division held that the trial court erred. Viewing the evidence in the light most favorable to the defendants, there was a rational view of the evidence under which the jury could conclude that, although the defendants were negligent in performing the repairs, their negligence was not a proximate cause of the plaintiff’s claimed accident.

Central to the Court’s analysis was the principle that negligence and proximate cause are not always “inextricably intertwined.” While there are circumstances where a finding of negligence necessarily compels a finding of causation, this was not such a case. The record contained evidence from which the jury could question whether the accident occurred as described—or at all—including the absence of corroborating witnesses, the lack of police involvement or towing documentation, and photographs of vehicle damage that the jury could reasonably find inconsistent with the plaintiff’s account of multiple high-speed impacts with a concrete barrier.

The jury’s deliberative note—asking whether it was required to assume that an accident occurred—further underscored that causation and even the occurrence of the accident itself were contested factual issues. The Second Department held that it was not error for the trial court to instruct the jury that it could consider whether the alleged accident occurred, and that the verdict sheet did not preclude such a determination. Under these circumstances, the jury’s finding that the defendants’ negligence was not a substantial factor in causing the plaintiff’s injuries was not irrational. Because there existed a valid line of reasoning and permissible inferences supporting the verdict, the trial court improperly substituted its judgment for that of the jury.

This decision serves as a reminder that C.P.L.R. §4404(a) motions based on legal insufficiency are subject to a demanding standard, and that courts must resist the temptation to disturb jury verdicts where issues of credibility, causation, and factual dispute are reasonably resolved by the trier of fact.

Giulia R. Marino, Esq.