Also known as:motions for JMOL · JMOL motion · JMOL motions · motion for judgment as a matter of law · Rule 50 motion
Written by attorneys · grounded in primary & secondary sources — see below
A procedural motion by which a party requests that the court enter judgment during a jury trial because the opposing party has failed to present legally sufficient evidence on an essential element of a claim or defense. The court may grant the motion only when a reasonable jury would lack a legally sufficient evidentiary basis to find for the nonmovant on that issue. The motion must be made before the case is submitted to the jury and must specify the judgment sought along with the supporting law and facts.
Sources & Authorities
How it applies
Common Examples
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Insufficient Reliance Evidence
Bianca, a banker, sued Red Investments after purchasing shares based on a friend's recommendation and a brochure. She admitted never reading the risk disclosures and offered only lay testimony about emails. After she rested, Red Investments moved for judgment as a matter of law on the securities fraud claim. The court granted the motion because no reasonable jury could find justifiable reliance on the record presented.
Timely Motion Before Submission
River Foundation sued its former executive Casey for misappropriating grant funds. After the foundation rested its case showing accounting discrepancies and exclusive control but no direct tracing to Casey's accounts, Casey moved for judgment as a matter of law. The motion was made before the case went to the jury and specified the judgment sought along with the factual deficiencies in the evidence.
Select any source to read its text and confirm it supports the definition.
Cases
Federal Rules
Casebooks
Age Discrimination Evidence Review
Mustafa Mahmoud sued his employer for age discrimination after termination. He presented evidence that his attendance records were accurate and that his supervisor showed age-based animus. The employer moved for judgment as a matter of law at the close of evidence. The court denied the motion after determining that a reasonable jury could find age was a motivating factor.
Reeves v. Sanderson Plumbing Products, Inc.530 U.S. 133, 150–51 (2000)
Due Process Bias Challenge
Mohan Malhotra sued a coal company after an adverse judgment. He argued that the presiding judge had received substantial campaign contributions from the defendant. The company moved for judgment as a matter of law on the bias claim. The court denied the motion after finding that the evidence created a jury issue on whether the contributions created an unconstitutional risk of bias.
Caperton v. A. T. Massey Coal Co.556 U.S. 868 (2009)
State Law Standard Application
Mariam Mansour sued a humanities center for breach of contract after a lecture cancellation. She presented evidence of damages under state law. The center moved for judgment as a matter of law arguing insufficient proof. The court denied the motion after determining that the evidence satisfied the state-law standard for a reasonable jury finding.
Gasperini v. Center for Humanities, Inc.518 U.S. 415, 429–431 (1996)
Patent Claim Construction Dispute
Malcolm McKinley sued a competitor for patent infringement over a dry-cleaning inventory system. The parties disputed the meaning of the term inventory. The competitor moved for judgment as a matter of law. The court denied the motion after determining that the evidence created a triable issue on whether the accused system met the properly construed claim limitations.
Markman v. Westview Instruments, Inc.517 U.S. 370 (1996)
Common questions
Frequently Asked
4
When may a party properly move for judgment as a matter of law?+
A party may move for judgment as a matter of law after it has been fully heard on an issue during a jury trial and 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 standard does the court apply when deciding a motion for judgment as a matter of law?+
The court must determine whether a reasonable jury would have a legally sufficient evidentiary basis to find for the nonmovant on the issue. If no such basis exists, the court may resolve the issue against the party and enter judgment.
Supporting sources
What happens if a party fails to renew a motion for judgment as a matter of law after the verdict?+
The party is barred on appeal from arguing that the evidence was legally insufficient to support the verdict. The failure to file a renewed motion under Rule 50(b) prevents appellate review of sufficiency.
Supporting sources
How does the court view the evidence on a motion for judgment as a matter of law?+
The court views the evidence in the light most favorable to the nonmoving party and draws all reasonable inferences in that party's favor. The motion is granted only when the evidence permits only one reasonable conclusion.
Supporting sources
517 U.S. 370 (1996)Civil Procedure
…of Markman’s independent claim 1 and dependent claim 10.[^maj-2] The District Court nevertheless granted Westview’s deferred motion for judgment as a matter of law, one of its reasons being that the term “inventory” in Markman’s patent encompasses “both cash inventory and the actual physical inventory of articles of clothing.” 772 F. Supp. 1535,…