Also known as: judgment as a matter of law · judgement as a matter of law · JML · Rule 50 motion
Written by attorneys · grounded in primary & secondary sources — see below
A procedural device authorizing a court to enter judgment during or after a jury trial when the evidence is legally insufficient for a reasonable jury to find for the nonmoving party on a claim or defense.
Jose Jimenez sued Jordan Dynamics for breach of contract, claiming the company failed to deliver custom parts on time. At trial, Jimenez presented no evidence that the contract required a specific delivery date. After both sides rested, Jordan Dynamics moved for judgment as a matter of law. The court granted the motion because the claim could succeed only with a favorable finding on the missing element.
Jonathan Jaffe sued Jenkins Apparel for trademark infringement. After the close of evidence but before the case went to the jury, Jenkins Apparel moved for judgment as a matter of law. The motion identified the judgment sought and the specific facts and law showing that Jaffe had failed to prove likelihood of confusion. The court considered the motion on the record.
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Joy Jiang sued Jaffe Securities for securities fraud. The district court denied Jaffe Securities' motion for summary judgment. At trial, after Jiang rested, Jaffe Securities renewed its request for judgment as a matter of law. The court granted the motion because the trial record contained no legally sufficient evidence on the element of scienter.
Javier Jimenez sued Jiang Textiles in federal court under a contract containing a forum-selection clause. After the jury was empaneled and evidence began, Jiang Textiles moved for judgment as a matter of law on the ground that the clause required dismissal. The court denied the motion as untimely under the governing procedural framework.
Jason Jung sued Jordan Dynamics for product liability. The defendant moved for summary judgment, arguing the plaintiff lacked evidence on causation. After the motion was denied and the case proceeded to trial, Jordan Dynamics moved for judgment as a matter of law at the close of Jung's case. The court granted the motion because the trial evidence remained insufficient.
Jordan Jenkins sued Jenkins Apparel for employment discrimination. The defendant moved for judgment as a matter of law after the plaintiff rested, pointing to the complete absence of evidence that the decisionmaker knew of the plaintiff's protected activity. The court granted the motion because no reasonable jury could find for Jenkins on that element.
The court asks whether a reasonable jury would have a legally sufficient evidentiary basis to find for the nonmoving party on the issue. If the answer is no, the court may resolve the issue against that party.
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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 supporting it.
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The party is barred on appeal from arguing that the evidence was legally insufficient to support the verdict.
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Both tests ask whether a reasonable jury could find for the nonmoving party. Appellate courts review both de novo under the same sufficiency-of-the-evidence inquiry.
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…Gasoline Products Co. v. Champlin Refining Co. , 283 U. S. 494 (1931), and Federal Rule of Civil Procedure 50(b)'s motion for 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…