Also known as: Rule 50(a) motions · 50(a) motion · 50(a) motions · JMOL motion · motion for judgment as a matter of law
Written by attorneys · grounded in primary & secondary sources — see below
A procedural device by which a party in a federal jury trial may seek entry of judgment as a matter of law after the opposing party has been fully heard on an issue. The court grants the motion when the record contains no legally sufficient evidentiary basis for a reasonable jury to find for the nonmovant on that issue under controlling law.
Rebecca Ross sued Radiance Media in federal court for securities fraud. After Ross rested, Radiance Media moved for judgment as a matter of law, arguing that Ross had admitted she never read the risk disclosures and offered no proof of justifiable reliance. The court granted the motion because the claim could succeed only with a favorable finding on that element and the record supplied no legally sufficient basis for it.
Rachel Ramirez sued Riverfront Developments for breach of contract and negligence after cargo spoiled. At the close of Ramirez's case, Riverfront Developments moved for judgment as a matter of law before submission to the jury, specifying the judgment sought and the absence of any evidence linking its refrigeration system to the loss. The court granted the motion because no reasonable jury could find causation on the record presented.
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Rhea Reynolds sued Royal Crest Hotels for age discrimination after her termination. Reynolds introduced evidence that her supervisor had made age-based comments and that her attendance records were accurate. The hotel moved for judgment as a matter of law at the close of Reynolds's case, contending the evidence failed to show age was a determinative factor. The court denied the motion because the record contained a legally sufficient basis for a reasonable jury to find for Reynolds.
Ronald Reed sued Riverstone Manufacturing alleging bias by the trial judge violated due process. After Reed rested, Riverstone Manufacturing moved for judgment as a matter of law, arguing the evidence of judicial bias was too speculative to support the claim. The court granted the motion because no reasonable jury could find a constitutional violation on the facts presented.
Rita Russell sued Radiance Media for personal injury in federal court under diversity jurisdiction. After Russell rested, Radiance Media moved for judgment as a matter of law on the ground that state law capped damages below the amount sought. The court denied the motion because the evidence permitted a reasonable jury to award damages within the statutory limit.
Roland Rhodes sued Royal Crest Hotels for patent infringement. After Rhodes rested, Royal Crest Hotels moved for judgment as a matter of law, arguing the evidence showed no infringement under the proper construction of the patent claims. The court granted the motion because the record supplied no legally sufficient basis for a reasonable jury to find infringement.
A party may make the motion at any time before the case is submitted to the jury after the opposing party has been fully heard on the issue. The motion must specify the judgment sought and the law and facts supporting it.
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The court asks whether a reasonable jury would have a legally sufficient evidentiary basis to find for the nonmovant on the issue. The court views the evidence in the light most favorable to the nonmovant and resolves the issue against that party only when the record is legally insufficient.
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The court is considered to have submitted the action to the jury. The movant must renew the motion under Rule 50(b) after the verdict to preserve a sufficiency challenge for appeal.
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Yes, if the circumstantial evidence still fails to supply a legally sufficient basis for a reasonable jury to find for the nonmovant on an essential element. The court does not weigh credibility but simply determines whether the record permits a verdict.
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…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,…