A judicial determination by the court on an issue that the law assigns exclusively to the judge rather than the jury.
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How its tested
Common Examples
6
JMOL on Causation Evidence
Antonio Alvarado sued Aether Technologies after a workplace accident. At the close of his case, Aether moved for judgment as a matter of law. The court granted the motion because no reasonable jury could find causation on the record presented.
Unconscionability Ruling
Alexandra Armstrong bought goods under a contract with Arcadia Retail containing a harsh arbitration clause. The court found the clause unconscionable at formation and refused to enforce it.
False Light Claim Dismissal
Audrey Ashton sued a news outlet for false light after a substantially true report. The court held the claim failed because the reporting was protected and could not support liability.
Adam Anderson completed his evidence in a contract trial. Before the case went to the jury, he moved for judgment as a matter of law and specified the supporting facts and law.
Summary Judgment Grant
Austin Abbott sued Ashford Manufacturing. After discovery, Ashford moved for summary judgment and showed no genuine dispute of material fact on any element of the claim.
Materiality Determination
Andrew Avery sued Basic Inc. for securities fraud. The district court ruled that the alleged misstatements were immaterial and granted summary judgment for the defendants.
Basic Inc. v. Levinson485 U.S. [224], at 238 1988
Basic Incorporated was a publicly traded company primarily engaged in manufacturing chemical refractories for the steel industry. As early as 1965 or 1966 Combustion Engineering expressed interest in acquiring Basic but was deterred by antitrust concerns. In 1976 regulatory action removed the antitrust barrier and Combustion's strategic plan listed an objective to acquire Basic for thirty million dollars.
Beginning in September 1976 Combustion representatives met and spoke by telephone with Basic officers and directors about a possible merger. During 1977 and 1978 Basic issued three public statements denying that merger negotiations were under way. On December 18 1978 Basic asked the New York Stock Exchange to suspend trading in its shares and announced it had been approached by another company concerning a merger.
The next day Basic's board endorsed Combustion's offer of forty-six dollars per share. On December 20 1978 Basic publicly announced approval of Combustion's tender offer for all outstanding shares. Respondents are former Basic shareholders who sold their stock after Basic's October 21 1977 public statement and before the December 1978 trading suspension.
Respondents brought a class action against Basic and its directors alleging that the three statements violated section 10(b) and Rule 10b-5 by misleading the market and causing sales at artificially depressed prices. The District Court certified the class under a presumption of reliance but granted summary judgment for the defendants on the ground that any misstatements were immaterial. The Court of Appeals for the Sixth Circuit affirmed class certification reversed the summary judgment and remanded the case. The Supreme Court granted certiorari.
When may a court grant judgment as a matter of law under Rule 50?
A court may grant the motion when a party has been fully heard on an issue and no reasonable jury would have a legally sufficient evidentiary basis to find for that party.
Who decides whether a contract clause is unconscionable?
The court decides unconscionability as a matter of law after giving the parties an opportunity to present evidence on commercial setting, purpose, and effect.
What happens if a party fails to renew a JMOL motion after verdict?
The party is barred on appeal from arguing that the evidence was legally insufficient to support the verdict.
Can a false light claim survive when the underlying report is substantially true?
No. The claim fails as a matter of law because false light cannot circumvent constitutional protections for substantially true speech or protected opinion.
509 U.S. 579, 592 (1993)
…announced by the Supreme Court. Our review here is, of course, very narrow: We will affirm the summary judgment only if, as a matter of law, the proffered evidence would have to be excluded at trial. The district court's power is far broader; were we to conclude that the expert testimony is not per se inadmissible, the district…