Article: Appellate review of multi-claim general verdicts: the life and premature death of the Baldwin principle.

I. INTRODUCTION

Consider the following scenario. A law student slips and falls in a dark hallway after hours. He brings a tort action against the law school alleging that it was negligent because (1) it failed to provide adequate lighting in the hallways at night and (2) it failed to provide sufficient notice that the floors had just been waxed. The judge instructs the jury to return a general verdict. After deliberating, the jury finds the law school liable. The law school feels wronged and appeals the case. On appeal, the circuit court finds that there was insufficient evidence to find the law school liable on the second theory of liability. Indeed, a sign had ...

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