Baltimore & Carolina Line v. Redman
In Baltimore & Carolina Line v. Redman, 295 U.S. 654, 55 S.Ct. 890, 79 L.Ed. 1636 (1935), the Supreme Court distinguished between cases where prior to the verdict the trial court expressly reserved decision on the question of the sufficiency of the evidence, and cases such as Slocum in which no such reservation was made, it being held in the former that the Seventh Amendment did not forbid entry of judgment notwithstanding a verdict. The scope of the Redman case was subsequently limited in Aetna Ins. Co. v. Kennedy, 301 U.S. 389, 57 S.Ct. 809, 81 L.Ed. 1177 (1937).