Also known as:FRCP 50 · Fed. R. Civ. P. 50 · Rule 50 · JMOL · judgment as a matter of law
Written by attorneys · grounded in primary & secondary sources — see below
A procedural rule permitting a court to enter judgment as a matter of law during or after a jury trial when the evidence is legally insufficient to support a verdict for the nonmoving party. The motion must identify the judgment sought and the supporting law and facts. Renewal after verdict preserves the issue for appeal.
Sources & Authorities
How it applies
Common Examples
6
Insufficient Evidence on Causation
Freya Freeman sued Frostline Textiles after a machine malfunction injured her arm. At trial she presented no expert testimony linking the defect to the injury. Frostline moved for judgment as a matter of law before the case went to the jury. The court granted the motion because no reasonable jury could find causation on the record presented.
Timely Motion Before Submission
Fatima Flores sued Fulton Shipping for unpaid wages. After both sides rested, Fulton moved for judgment as a matter of law and specified the missing proof of an employment contract. The court considered the motion because it was made before the case reached the jury.
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Cases
Federal Rules
Casebooks
Hornbooks
Finn Fletcher sued Falcon Dynamics for breach of a supply agreement. At trial he presented no evidence of damages. Falcon moved for judgment as a matter of law after the close of evidence. The court granted the motion because no reasonable jury could find for Fletcher on the record presented.
No Reasonable Jury Finding
Fiona Foster sued Frontier Capital alleging securities fraud. After the close of evidence the court determined that the record contained no proof of scienter. It entered judgment as a matter of law for the defendant.
Anderson v. Liberty Lobby, Inc.477 U.S. 242, 250 (1986)
Post-Verdict Renewal
Forrest Falconer obtained a jury verdict against a state university on a contract claim. The university renewed its motion for judgment as a matter of law. The court denied the motion but preserved the sufficiency issue for appellate review.
Gasperini v. Center for Humanities, Inc.518 U.S. 415, 429–431 (1996)
Federal Standard Applied
Felicia Fuentes sued a rural cooperative in federal court under diversity jurisdiction. The defendant moved for judgment as a matter of law on a state-law negligence claim. The court applied the federal sufficiency standard rather than a state rule that would have sent the issue to the jury.
Byrd v. Blue Ridge Rural Electrical Cooperative, Inc.356 U.S. 525, 537–38 (1958)
Common questions
Frequently Asked
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When must a Rule 50 motion be made?+
A motion for judgment as a matter of law may be made at any time before the case is submitted to the jury. The motion must specify the judgment sought and the law and facts that entitle the movant to relief.
Supporting sources
What happens if the court denies a Rule 50(a) motion?+
The court is considered to have submitted the action to the jury. The movant may renew the motion after the verdict under Rule 50(b).
Supporting sources
How does Rule 50 relate to summary judgment?+
The standard for granting judgment as a matter of law under Rule 50 mirrors the standard for summary judgment under Rule 56. Both ask whether a reasonable jury could find for the nonmoving party.
Supporting sources
356 U.S. 525, 537–38 (1958)Civil Procedure
…the plaintiff and thus deprive the defendant, who had not rested, of his right to offer evidence in defense of plaintiff's case. Rule 50, Fed.Rules Civ. Proc. It is urged by respondent that, from the colloquy between the district judge and counsel, which, as stated, is set forth in substance in Mr. Justice Frankfurter's…