/en-TY-tuld too JUJ-muhnt az uh MAT-ur uv LAW/·phrase
Also known as:entitlement to judgment as a matter of law · entitles to judgment as a matter of law · JMOL · judgment as a matter of law · Rule 50
Written by attorneys — see sources below.
An evidentiary standard that permits a court to enter judgment without trial or to direct a verdict when the record shows no genuine dispute of material fact and the moving party prevails under the applicable substantive law.
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How its tested
Common Examples
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JMOL on Missing Causation Element
After Elm Eco rested its public-nuisance case against Pinnacle Clean, the defendant moved for judgment as a matter of law. The only evidence of causation consisted of photographs taken weeks after a storm and lay testimony about odors near the outfall. Because no reasonable jury could find causation on that record, the court granted the motion and entered judgment for Pinnacle Clean.
Timely JMOL Motion Before Submission
Red Investments moved for judgment as a matter of law after Bianca rested her securities-fraud case but before the matter went to the jury. The motion identified the missing elements of justifiable reliance and knowingly false statements and requested judgment on the entire claim. The court granted the motion because the procedural requirements were satisfied and the evidence was legally insufficient.
Global Cargo moved for summary judgment on Sean’s misclassification claim, supporting the motion with a dispatcher’s declaration and selected GPS logs. Sean opposed with uncited delivery receipts showing late arrivals that bore on the degree of control. Because the conflicting materials created a genuine dispute of material fact on an essential element, the court denied the motion.
One-Sided Evidence at Summary Judgment
Liberty Lobby moved for summary judgment in a defamation action, arguing that the record contained no clear and convincing evidence of actual malice. The nonmovant offered only conclusory allegations without specific facts. The court granted the motion because no reasonable jury could find for the plaintiff on the dispositive issue.
Anderson v. Liberty Lobby, Inc.477 U.S. 242, 250 (1986)
In October 1981, The Investigator magazine published two articles entitled "The Private World of Willis Carto" and "Yockey: Profile of an American Hitler," along with a shorter introductory article. These articles portrayed respondent Liberty Lobby, Inc., a not-for-profit corporation and self-described citizens' lobby, and its founder Willis A. Carto as neo-Nazi, anti-Semitic, racist, and Fascist.
Respondents filed a diversity libel action in the United States District Court for the District of Columbia against petitioners Jack Anderson, the publisher, Bill Adkins, and the Investigator Publishing Co., alleging that 28 statements and 2 illustrations in the articles were false and derogatory. Following discovery, petitioners moved for summary judgment under Federal Rule of Civil Procedure 56. In support, they submitted an affidavit from Charles Bermant, the author of the articles, stating that he had spent substantial time researching from a wide variety of sources and believed the facts to be truthful, along with an appendix detailing sources for each allegedly libelous statement.
Respondents opposed the motion, asserting inaccuracies and that Bermant had relied on patently unreliable sources, and presented evidence that editor William McGaw had told Adkins before publication that the articles were terrible and ridiculous.
The District Court held that respondents were limited-purpose public figures to whom the New York Times standards applied. After reviewing the evidence, the District Court granted summary judgment to petitioners.
The Court of Appeals for the District of Columbia Circuit affirmed as to 21 statements and reversed as to 9. It held that the requirement that actual malice be proved by clear and convincing evidence need not be considered at the summary judgment stage.
The Supreme Court granted certiorari because the holding conflicted with decisions of several other Courts of Appeals.
Celotex moved for summary judgment in a wrongful-death action, pointing to the absence of any evidence that its product caused the decedent’s exposure. The plaintiff produced no affidavits or other materials showing a genuine dispute on causation. The court granted the motion because the movant had shown that the nonmovant could not carry its burden at trial.
Celotex Corp. v. Catrett477 U.S. 317, 323 (1986)
In September 1980 respondent Catrett, as administratrix of her husband's estate, commenced a wrongful-death action in the Superior Court of the District of Columbia against fifteen named corporations including petitioner Celotex Corporation.
The complaint alleged that her husband Louis H. Catrett died in 1979 from exposure to asbestos products manufactured or distributed by the defendants. The action was removed to the United States District Court for the District of Columbia on diversity grounds.
After extensive discovery Celotex filed a motion for summary judgment in September 1981 asserting that respondent had failed to produce any evidence that the decedent had been exposed to Celotex asbestos products. In response respondent produced a transcript of the decedent's deposition taken in a separate California proceeding, a letter from an official of one of Celotex's former insurance companies, and a letter from one of Celotex's customers.
In July 1982 the District Court granted summary judgment to Celotex on the ground that respondent had made no showing of exposure to Celotex products in the District of Columbia or elsewhere within the statutory period. Respondent appealed only that ruling.
A divided panel of the Court of Appeals for the District of Columbia Circuit reversed, holding that Celotex had failed to meet its initial burden because it made no effort to adduce affirmative evidence supporting its motion. The Supreme Court granted certiorari to resolve a conflict among the circuits concerning the proper standard under Rule 56.
Adickes sued Kress after being refused service in a lunch counter. Kress moved for summary judgment, and the record contained no evidence that a police officer was present pursuant to a conspiracy. The court granted the motion because the plaintiff had failed to produce facts that would permit a reasonable jury to draw the necessary inference.
Adickes v. S.H. Kress & Co.398 U.S. 144, 152 (1970)
Sandra Adickes, a white school teacher from New York, was working as a volunteer teacher at a Freedom School for Negro children in Hattiesburg, Mississippi, during the summer of 1964. On August 14, 1964, Adickes went with six of her Negro students to the Hattiesburg Public Library, where the librarian refused to allow the students to use the library and summoned the chief of police, who ordered the group to leave. The group then went to the S. H. Kress & Co. store in Hattiesburg to have lunch. Adickes filed suit against Kress in the United States District Court for the Southern District of New York seeking damages under 42 U.S.C. § 1983.
After the group sat down at the lunch counter, a policeman entered the store and observed them. A waitress took the orders of the Negro students but refused to serve Adickes on the ground that she was a white person in the company of Negroes. The group left the store without being served. As they reached the sidewalk, the same policeman arrested Adickes on a vagrancy charge.
The vagrancy charge against Adickes was subsequently changed, and she was tried and acquitted. Her complaint contained two counts under § 1983. One count alleged that Kress had refused her service pursuant to a custom of the community to segregate the races in public eating places that was enforced by the State. The other count alleged that the refusal of service and the arrest were the product of a conspiracy between Kress employees and the Hattiesburg police.
Kress moved for summary judgment on the conspiracy count and submitted depositions from the store manager, the waitress, and the arresting officers, along with affidavits from police officials, all denying any agreement or communication with the police about refusing service or making the arrest. Adickes opposed the motion by pointing to her deposition statement and an unsworn statement from a Kress employee indicating that a policeman had been in the store at the time of the refusal. The District Court granted summary judgment on the conspiracy count, holding that Adickes had failed to allege facts from which a conspiracy might be inferred. After a trial on the custom count, the District Court directed a verdict for Kress because Adickes had not proved other instances of whites being refused service while in the company of Negroes.
The Court of Appeals for the Second Circuit affirmed the District Court's rulings on both counts. The Supreme Court granted certiorari to review the case.
When may a party move for judgment as a matter of law under Rule 50?
A party may move for judgment as a matter of law 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 that judgment.
Supporting sources
What standard governs entry of summary judgment under Rule 56(a)?
The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.
Supporting sources
How does the standard for judgment as a matter of law compare to the standard for summary judgment?
Both standards ask whether a reasonable jury could find for the nonmovant on the issue. Rule 50 applies after a party has been fully heard at trial. Rule 56 applies on the basis of the pretrial record.
Supporting sources
What must a movant show to obtain judgment as a matter of law on a particular element?
The movant must demonstrate that the claim or defense can be maintained or defeated only with a favorable finding on that issue and that a reasonable jury would lack a legally sufficient evidentiary basis to make that finding.
Supporting sources
…the plaintiff and thus deprive the defendant, who had not rested, of his right to offer evidence in defense of plaintiff's case.
Rule 50
, Fed. Rules Civ. Proc. It is urged by respondent that, from the colloquy between the district judge and counsel, which, as stated, is set forth in substance in Mr. Justice Frankfurter's…