Also known as: judgements as a matter of law · judgment notwithstanding the verdict · JMOL · directed verdict
Written by attorneys — see sources below.
A procedural ruling by which a court removes an issue or claim from the jury during or after a trial. The ruling rests on a determination that the evidence supplies no legally sufficient basis for a reasonable jury to find for the nonmoving party on that issue or claim.
John Jones sued Jefferson Trust for negligence after a branch fell on his car. At trial Jones presented only photographs of the scene and testimony that the tree looked old. After Jones rested, Jefferson Trust moved for judgment as a matter of law on the element of causation. The court granted the motion because no reasonable jury could find that the bank’s conduct caused the injury.
Jasmine Jordan sued Jiang Textiles for breach of contract. After both sides rested, Jiang Textiles moved for judgment as a matter of law, specifying the contract-formation issue and the facts showing no meeting of the minds. The motion was made before the case went to the jury and identified the controlling law and supporting evidence.
Jorge Juarez sued Juarez Holdings for employment discrimination. After discovery the company moved for summary judgment, citing affidavits and documents showing no adverse action. The court granted the motion because the record contained no genuine dispute of material fact and the company was entitled to judgment as a matter of law on the same basis that would support a later Rule 50 ruling.
Jacob Jennings sued Jensen Farms for product liability. The jury returned a verdict for Jennings. Jensen Farms renewed its earlier motion for judgment as a matter of law, arguing the evidence on defect was legally insufficient. The court denied the motion because a reasonable jury could have found for Jennings on the record presented.
William Gasperini, a journalist and photographer who had taken over 5,000 slide transparencies while reporting in Central America, agreed in 1990 to supply 300 of his original color transparencies to The Center for Humanities, Inc., for use in an educational videotape titled Conflict in Central America. After the project concluded, the Center could not locate or return the transparencies, prompting Gasperini to pursue legal remedies for their loss. Gasperini, a California citizen, sued the Center, a New York corporation with its principal place of business in New York, in the United States District Court for the Southern District of New York. He invoked diversity jurisdiction under 28 U.S.C. § 1332 and alleged state-law claims for breach of contract, conversion, and negligence. The Center conceded liability, so the case proceeded to trial solely on damages. At the three-day jury trial, Gasperini's expert testified that the industry standard valued each lost transparency at $1,500 as the average license fee over the photographer's copyright term. Gasperini testified that his photography earnings from 1984 through 1993 totaled just over $10,000 and that he planned to publish a book of his best Central American photographs. The jury returned a verdict of $450,000, or $1,500 for each of the 300 slides. The Center moved for a new trial under Federal Rule of Civil Procedure 59, invoking both the federal standard and New York Civil Practice Law and Rules § 5501(c). The District Court denied the motion without comment. The Court of Appeals for the Second Circuit vacated the judgment after applying the New York deviates-materially standard itself. The Second Circuit surveyed Appellate Division decisions on similar awards and concluded that the verdict materially deviated from reasonable compensation because many slides were generic and Gasperini had limited earnings. It ordered a new trial unless Gasperini accepted a reduction to $100,000. The Supreme Court granted certiorari to resolve the conflict over the proper standard.
View caseJustin Jarvis, a shareholder, sued a corporation alleging improper political expenditures. After trial the corporation moved for judgment as a matter of law, pointing to undisputed corporate records showing compliance with disclosure rules. The court granted the motion because no reasonable jury could find a violation on the evidence.
Citizens United is a nonprofit corporation with an annual budget of about $12 million. Most of its funds come from donations by individuals, though it accepts a small portion from for-profit corporations. In January 2008, Citizens United released a 90-minute documentary film entitled Hillary: The Movie. The film mentions Senator Hillary Clinton by name and depicts interviews with political commentators, most of them critical of her. Hillary was released in theaters and on DVD, but Citizens United wanted to increase distribution by making the film available through video-on-demand. In December 2007, a cable company offered to make Hillary available on a video-on-demand channel called Elections '08 for a payment of $1.2 million. The proposal was to make the film available to viewers free of charge. To promote the video-on-demand offering, Citizens United produced two 10-second ads and one 30-second ad. Each ad includes a short statement about Senator Clinton followed by the name of the movie and the movie's website address. Citizens United desired to promote the offering by running the advertisements on broadcast and cable television within 30 days of primary elections. Before the Bipartisan Campaign Reform Act of 2002, federal law prohibited corporations from using general treasury funds to make independent expenditures that expressly advocate the election or defeat of a candidate in connection with certain federal elections. BCRA §203 amended the law to prohibit any electioneering communication. An electioneering communication is any broadcast, cable, or satellite communication that refers to a clearly identified candidate for federal office and is made within 30 days of a primary or 60 days of a general election when publicly distributed so that it can be received by 50,000 or more persons in a relevant state. Concerned about possible civil and criminal penalties for violating 2 U.S.C. §441b, Citizens United filed suit in the United States District Court for the District of Columbia in December 2007. It sought declaratory and injunctive relief, arguing that §441b is unconstitutional as applied to Hillary and that BCRA's disclaimer, disclosure, and reporting requirements are unconstitutional as applied to Hillary and the ads. The District Court denied Citizens United's motion for a preliminary injunction and granted the Federal Election Commission's motion for summary judgment. The Supreme Court noted probable jurisdiction. The case was reargued after the Court requested supplemental briefs addressing whether Austin v. Michigan Chamber of Commerce and the relevant portion of McConnell v. Federal Election Commission should be overruled.
View caseJune Jiang was charged with possession of a firearm found in a car she occupied. The prosecution relied solely on the statutory presumption of possession. After the close of evidence June Jiang moved for judgment as a matter of law. The court granted the motion because the presumption alone did not supply a legally sufficient basis for a reasonable jury to convict.
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 caseA party may move for judgment as a matter of law 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
The court grants the motion if a party has been fully heard on an issue and a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue. The court resolves the issue against the party and may enter judgment on a claim or defense that can be maintained or defeated only with a favorable finding.
Supporting sources
Yes. A party must move for judgment as a matter of law under Rule 50(a) before the case is submitted to the jury. Without that timely motion a party cannot renew the request after the verdict under Rule 50(b).
Supporting sources
When the case turns on witness credibility a court almost never grants judgment as a matter of law. If reasonable jurors could believe either side the issue must go to the jury.
…nor a public figure. It added that, if he were, the resulting application of the New York Times standard would require a directed verdict for respondent. Because some statements in the article constituted libel per se under Illinois law, the court submitted the case to the jury under instructions that withdrew from its…