Also known as: judgment as a matter of law · judgment as matter of law · JNOV · judgment notwithstanding the verdict · JMOL · Rule 50 motion
Written by attorneys · grounded in primary & secondary sources — see below
A ruling by which a court in a jury trial resolves an issue or the entire case against a party when the evidence supplies no legally sufficient basis for a reasonable jury to find for that party on the claim or defense. The ruling may occur before or after verdict and requires the movant to identify the controlling law and supporting facts.
John Jones sued Jordan Dynamics for breach of a supply contract. After Jones presented his case-in-chief, Jordan Dynamics moved for judgment as a matter of law, arguing that the record contained no evidence of any contractual breach. The court granted the motion and entered judgment for Jordan Dynamics because Jones had failed to produce evidence on an essential element of his claim.
Joanna Jung sued Jenkins Apparel for employment discrimination. At the close of all evidence but before the case went to the jury, Jenkins Apparel moved for judgment as a matter of law and specified the missing elements of Jung's prima facie case along with the governing legal standard. The court considered the motion because it had been made before submission to the jury and contained the required statement of law and facts.
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Jamal Jefferson sued Jaffe Securities for negligence after a stock-trade error. Jaffe Securities moved for judgment as a matter of law at the close of all evidence, pointing to undisputed records showing that Jefferson's losses resulted from market forces rather than the alleged error. The court granted the motion because the evidence supplied no legally sufficient basis for a reasonable jury to find causation.
Judy Jacobs sued Jacob Jennings for defamation. Jennings moved for judgment as a matter of law after all evidence, contending that Jacobs could not produce evidence of actual malice sufficient to meet the clear-and-convincing standard. The court granted the motion after determining that the record lacked evidence from which a reasonable jury could find actual malice by that heightened measure.
James Johnson was charged with possession of a firearm. The prosecution relied on a statutory presumption linking presence in a vehicle to possession. Johnson moved for judgment as a matter of law at the close of the government's case, arguing that the presumption alone could not support a finding of possession beyond a reasonable doubt. The court granted the motion because the evidence failed to establish the required connection.
Jiang Textiles obtained a jury verdict that included a large punitive award against Exxon Shipping Co. Exxon Shipping Co. renewed its motion for judgment as a matter of law, contending that the punitive-to-compensatory ratio exceeded constitutional limits. The court reduced the award after concluding that the evidence could not support the jury's punitive figure under governing maritime standards.
A party must file both a pre-verdict motion under Rule 50(a) and a renewed post-verdict motion under Rule 50(b). Failure to file the renewed motion bars appellate review of the sufficiency of the evidence.
The court applies a legal-sufficiency test. It asks whether a reasonable jury could find for the nonmoving party on the issue. The court does not weigh credibility or resolve factual disputes.
Yes. Rule 50(a)(1)(B) authorizes the court to grant the motion against a party on any claim or defense that can be maintained or defeated only with a favorable finding on a particular issue.
Both standards ask whether the evidence would permit a reasonable jury to find for the nonmoving party. Summary judgment under Rule 56 uses the same sufficiency inquiry that governs Rule 50 motions during or after trial.
…the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." By its very terms, this standard provides that the mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary…