Also known as: FRCP Rule 50 · Fed. R. Civ. P. 50 · Rule 50 · judgment as a matter of law · JMOL
Written by attorneys — see sources below.
A procedural rule that authorizes a court in a jury trial to resolve an issue against a party who has been fully heard when the evidence provides no legally sufficient basis for a reasonable jury to find for that party.
Felicity French sued Fusion Power after a workplace accident. At trial she presented only photographs of the site and coworker statements about general conditions. Fusion Power moved for judgment as a matter of law on the causation element after she rested. The court granted the motion because no reasonable jury could find causation on the record presented.
Fiona Foster sued Frontier Capital for breach of contract. After she rested, Frontier Capital moved for judgment as a matter of law before the case went to the jury. The motion identified the damages element and the specific evidentiary gaps that entitled it to judgment.
Fatima Flores sued Freeman Engineering alleging defective design. After she rested at trial Freeman Engineering moved for judgment as a matter of law on the design defect claim. The court granted the motion because the record contained no legally sufficient evidence on which a reasonable jury could find for Flores.
Fumiko Fujimoto sued Fidelity Trust after a vehicle accident. The court instructed the jury on a statutory presumption of negligence. Fidelity Trust moved for judgment as a matter of law at the close of evidence. The court granted the motion because the presumption alone did not supply a legally sufficient basis for the verdict.
In March 1973, three adult male respondents and a sixteen-year-old girl were traveling in a Chevrolet on the New York State Thruway when the car was stopped for speeding. Police observed two loaded handguns weighing approximately six pounds in an open handbag on the front floor or seat beside the girl, who admitted the bag belonged to her. A machinegun and heroin were discovered in the trunk after it was pried open. The four were tried together in Ulster County Court for possession of the handguns and trunk items. The trial judge instructed the jury regarding the statutory presumption that the presence of firearms in the automobile constituted evidence of possession by all occupants. The jury found the three adult males guilty of handgun possession but acquitted everyone of the trunk charges. The convictions were affirmed by the Appellate Division without opinion. The New York Court of Appeals also affirmed. The respondents sought federal habeas corpus relief in the Southern District of New York. The district court granted the writ on the ground that the presumption could not support the convictions on these facts. The Second Circuit affirmed the grant of the writ, though on the basis that the statute was unconstitutional on its face. The Supreme Court granted certiorari to consider the procedural and substantive issues raised by the lower federal courts' decisions.
View caseFaith Fitzgerald obtained a jury verdict against Frontier Capital that included substantial punitive damages. Frontier Capital renewed its motion for judgment as a matter of law after the verdict. The court reduced the punitive award because the evidence did not support the amount under the applicable legal standard.
In March 1989 the Exxon Valdez supertanker grounded on Bligh Reef in Prince William Sound, Alaska, releasing millions of gallons of crude oil. Exxon Shipping Company, the vessel's owner and now known as SeaRiver Maritime, Inc., together with its parent Exxon Mobil Corporation, confronted widespread liability from the spill. The company settled a class action brought by more than 32,000 commercial fishermen, Native Americans, landowners, and others for $2.5 billion in compensatory damages. Exxon also pleaded guilty to violations of the Clean Water Act, the Migratory Bird Treaty Act, and the Refuse Act, paying $150 million in criminal fines, and spent an additional $2.1 billion on cleanup. Respondents, other persons whose businesses and livelihoods were disrupted by the spill, filed this civil action seeking punitive damages. The United States District Court for the District of Alaska divided the plaintiffs into three classes and conducted a three-phase trial. In the first phase the jury found Exxon Shipping Company and Captain Joseph Hazelwood, the ship's master, reckless and therefore potentially liable for punitive damages. In the second phase the jury awarded $5 billion in punitive damages against Exxon. The District Court later reduced the punitive award to $2.5 billion. On appeal the Ninth Circuit reinstated the jury's original $5 billion punitive damages award. The Supreme Court granted certiorari to consider whether the $2.5 billion punitive damages award was excessive under maritime law.
View caseFelipe Figueroa sued Fusion Power for employment discrimination. After he rested at trial Fusion Power moved for judgment as a matter of law. The court denied the motion because the record contained evidence that, if believed, would permit a reasonable jury to find for Figueroa on the disputed element.
In October 1981, The Investigator magazine published two articles entitled "The Private World of Willis Carto" and "Yockey: Profile of an American Hitler," along with a shorter introductory article. These articles portrayed respondent Liberty Lobby, Inc., a not-for-profit corporation and self-described citizens' lobby, and its founder Willis A. Carto as neo-Nazi, anti-Semitic, racist, and Fascist. Respondents filed a diversity libel action in the United States District Court for the District of Columbia against petitioners Jack Anderson, the publisher, Bill Adkins, and the Investigator Publishing Co., alleging that 28 statements and 2 illustrations in the articles were false and derogatory. Following discovery, petitioners moved for summary judgment under Federal Rule of Civil Procedure 56. In support, they submitted an affidavit from Charles Bermant, the author of the articles, stating that he had spent substantial time researching from a wide variety of sources and believed the facts to be truthful, along with an appendix detailing sources for each allegedly libelous statement. Respondents opposed the motion, asserting inaccuracies and that Bermant had relied on patently unreliable sources, and presented evidence that editor William McGaw had told Adkins before publication that the articles were terrible and ridiculous. The District Court held that respondents were limited-purpose public figures to whom the New York Times standards applied. After reviewing the evidence, the District Court granted summary judgment to petitioners. The Court of Appeals for the District of Columbia Circuit affirmed as to 21 statements and reversed as to 9. It held that the requirement that actual malice be proved by clear and convincing evidence need not be considered at the summary judgment stage. The Supreme Court granted certiorari because the holding conflicted with decisions of several other Courts of Appeals.
View caseA party may move 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.
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The court may grant the motion when a party has been fully heard on an issue and a reasonable jury would lack a legally sufficient evidentiary basis to find for that party.
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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).
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Rule 50 applies after a party has been fully heard at trial. Rule 56 applies before trial when the record shows no genuine dispute of material fact.
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Yes. A party that fails to file a renewed motion under Rule 50(b) is barred on appeal from arguing that the evidence was legally insufficient to support the verdict.
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