Also known as:FRCP 50 · Fed. R. Civ. P. 50 · rule 50 motion · judgment as a matter of law · Rule 50(a) · JMOL
Written by attorneys · grounded in primary & secondary sources — see below
A procedural rule permitting a court to enter judgment as a matter of law when a party has been fully heard on an issue during a jury trial and no reasonable jury would have a legally sufficient evidentiary basis to find for that party.
Sources & Authorities· 7 primary sources
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Cases
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How it applies
Common Examples
6
Causation Evidence Challenged Mid-Trial
Elm Eco rested after offering photographs of discolored water near Pinnacle Clean's outfall, resident testimony about odors and respiratory complaints, and a state inspection report. Pinnacle Clean moved for judgment as a matter of law before submission to the jury, arguing the evidence supplied no legally sufficient basis for a reasonable jury to find causation on the nuisance claim. The court took the motion under advisement and submitted the case to the jury.
Timely Motion Specifies Judgment Sought
After Sean rested in his wage misclassification suit against Global Cargo, the company moved before the case went to the jury. The motion expressly requested judgment on the employee-status claim and identified the controlling law plus the facts showing insufficient evidence of control. The court considered the motion on its merits rather than rejecting it for procedural defects.
Summary Judgment Motion Filed Post-Discovery
Ridge Retail moved for summary judgment on Dusk Outlet's breach and negligence claims twenty-five days after the final discovery deadline. The motion identified both claims and asserted that the spreadsheet, affidavit, and complaint logs established no genuine dispute of material fact. The court evaluated whether the movant had shown entitlement to judgment as a matter of law on the record presented.
Defendant Moves Without Resting
Metro Properties moved for judgment as a matter of law at the close of Harper Office Investments' case on the earnest-money claim. The court sustained the motion without allowing Metro to present its own evidence on material breach. On appeal the reviewing court held that the ruling improperly deprived Metro of its opportunity to offer a defense.
Byrd v. Blue Ridge Rural Electrical Cooperative, Inc.356 U.S. 525, 537–38 (1958)
Movant Must Show Absence of Genuine Dispute
Celotex moved for summary judgment in the asbestos wrongful-death action, pointing to the absence of evidence that its product caused the decedent's exposure. Catrett responded with no affirmative proof linking the product to the injury. The court granted the motion because the record contained no triable issue on causation.
Celotex Corp. v. Catrett477 U.S. 317, 323 (1986)
Jury Instructions Preserve Fact Questions
Del Monte Dunes presented evidence that the city's repeated permit denials lacked a reasonable relationship to any legitimate public purpose. The trial court instructed the jury to decide whether the regulatory actions substantially advanced a legitimate objective. The jury returned a verdict for the developer, and the court entered judgment on that finding rather than directing a contrary result as a matter of law.
City of Monterrey v. Del Monte Dunes at Monterrey, Ltd.526 U.S. 687, 734 (1999)
Common questions
Frequently Asked
5
When may a party move for judgment as a matter of law under Rule 50?+
A 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. The court may grant the motion only after the opposing party has been fully heard on the issue.
Supporting sources
What standard governs whether the court should grant a Rule 50 motion?+
The court grants the motion when the record supplies no legally sufficient evidentiary basis for a reasonable jury to find for the nonmovant on the claim or defense. The court views the evidence in the light most favorable to the nonmovant and draws all reasonable inferences in that party's favor. Credibility determinations and weighing of evidence remain for the jury.
What happens if the court denies a timely Rule 50(a) motion and the jury returns a verdict?+
The court is deemed to have submitted the action to the jury. The movant may renew the motion under Rule 50(b) after the verdict. Failure to file a renewed motion bars the party from challenging the sufficiency of the evidence on appeal.
Supporting sources
How does Rule 50 differ from summary judgment under Rule 56?+
Rule 50 applies after a party has been fully heard at trial and tests whether the evidence is legally sufficient for a jury. Rule 56 applies before trial and tests whether the record shows no genuine dispute of material fact. Both standards ultimately ask whether a reasonable jury could find for the nonmovant.
Supporting sources
May a court grant judgment as a matter of law by reweighing witness credibility?+
No. The court may not substitute its own credibility assessments or weigh conflicting testimony. Once a jury has returned a verdict supported by legally sufficient evidence, the judge may set it aside only through the mechanisms permitted by Rule 50 or by ordering a new trial.
Supporting sources
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judgment as a matter of law
, see 9A C. Wright & A. Miller, Federal Practice and Procedure § 2522, pp. 244-246 (2d ed. 1995). See also Parklane Hosiery Co. v. Shore , 439 U. S. 322, 335-337 (1979) (issue preclusion…
judgment
is proper, a court ordinarily must look at the record in the light most favorable to the party opposing the
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, drawing all inferences most…
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s for a new trial or for
judgment as a matter of law
. The Court of Appeals affirmed. 95 F. 3d 1422 (CA9 1996). The court first
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d that the District Court did not err in allowing Del Monte Dunes' regulatory takings claim to be tried to a…