Also known as: judgements as a matter of law · judgment notwithstanding the verdict · JMOL · directed verdict
Written by attorneys · grounded in primary & secondary sources — see below
A procedural ruling by which a court removes an issue or claim from the jury during or after a trial. The ruling rests on a determination that the evidence supplies no legally sufficient basis for a reasonable jury to find for the nonmoving party on that issue or claim.
John Jones sued Jefferson Trust for negligence after a branch fell on his car. At trial Jones presented only photographs of the scene and testimony that the tree looked old. After Jones rested, Jefferson Trust moved for judgment as a matter of law on the element of causation. The court granted the motion because no reasonable jury could find that the bank’s conduct caused the injury.
Jasmine Jordan sued Jiang Textiles for breach of contract. After both sides rested, Jiang Textiles moved for judgment as a matter of law, specifying the contract-formation issue and the facts showing no meeting of the minds. The motion was made before the case went to the jury and identified the controlling law and supporting evidence.
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Jorge Juarez sued Juarez Holdings for employment discrimination. After discovery the company moved for summary judgment, citing affidavits and documents showing no adverse action. The court granted the motion because the record contained no genuine dispute of material fact and the company was entitled to judgment as a matter of law on the same basis that would support a later Rule 50 ruling.
Jacob Jennings sued Jensen Farms for product liability. The jury returned a verdict for Jennings. Jensen Farms renewed its earlier motion for judgment as a matter of law, arguing the evidence on defect was legally insufficient. The court denied the motion because a reasonable jury could have found for Jennings on the record presented.
Justin Jarvis, a shareholder, sued a corporation alleging improper political expenditures. After trial the corporation moved for judgment as a matter of law, pointing to undisputed corporate records showing compliance with disclosure rules. The court granted the motion because no reasonable jury could find a violation on the evidence.
June Jiang was charged with possession of a firearm found in a car she occupied. The prosecution relied solely on the statutory presumption of possession. After the close of evidence June Jiang moved for judgment as a matter of law. The court granted the motion because the presumption alone did not supply a legally sufficient basis for a reasonable jury to convict.
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 relief.
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The court grants the motion if a party has been fully heard on an issue and a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue. The court resolves the issue against the party and may enter judgment on a claim or defense that can be maintained or defeated only with a favorable finding.
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Yes. A party must move for judgment as a matter of law under Rule 50(a) before the case is submitted to the jury. Without that timely motion a party cannot renew the request after the verdict under Rule 50(b).
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When the case turns on witness credibility a court almost never grants judgment as a matter of law. If reasonable jurors could believe either side the issue must go to the jury.
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…nor a public figure. It added that, if he were, the resulting application of the New York Times standard would require a directed verdict for respondent. Because some statements in the article constituted libel per se under Illinois law, the court submitted the case to the jury under instructions that withdrew from its…