Also known as: motions for judgment · motion for judgment on the pleadings · MJ
Written by attorneys — see sources below.
A procedural device by which a party in a jury trial requests the court to enter judgment in its favor because the opposing party has failed to produce evidence legally sufficient for a reasonable jury to find for that party on a claim or defense. The motion may be made at any time before the case is submitted to the jury and must specify the judgment sought along with the supporting law and facts.
Marco Marquez sued Marathon Logistics for breach of contract after a shipment arrived late. At the close of Marco's case the judge found no evidence that the delay caused any compensable loss. The court granted Marathon's motion for judgment as a matter of law because Marco had not produced evidence that would allow a reasonable jury to find damages.
Miles Montgomery sued Metro Bank for wrongful termination. After both sides rested but before the jury received the case, Metro moved for judgment as a matter of law. The motion listed the missing element of causation and the supporting testimony. The court considered the motion because it was made before the case went to the jury.
Marcus Mitchell was tried for fraud. Before the case was submitted to the jury the evidence showed only ambiguous billing records and no proof of intent. The court granted Marcus's motion for judgment as a matter of law because no rational juror could find every element beyond a reasonable doubt.
On July 29, 1972, the body of Mary Houston Cole was discovered in a secluded church parking lot in Chesterfield County, Virginia. She had been shot twice at close range with a .38-caliber pistol. The victim had last been seen alive the previous evening in the company of petitioner Hugh Jackson, who was carrying a .38-caliber pistol. Jackson had befriended Cole while he was imprisoned on a disorderly conduct charge at the local county jail. After his release she arranged for him to live in the home of her son and daughter-in-law. On the day of the killing Jackson had been drinking and had spent considerable time shooting at targets with his revolver. Late in the afternoon he unsuccessfully attempted to persuade Cole to drive him to North Carolina. She instead drove him to a local diner where both were observed by several police officers. A deputy sheriff later observed Jackson and Cole preparing to leave the diner in her car. Jackson was in possession of his revolver and a kitchen knife was visible in the vehicle. Cole's body was found the following day and a half later, naked from the waist down with her slacks beneath her body. Six cartridge cases fired from Jackson's gun were recovered nearby. Jackson drove the victim's car to North Carolina, made a short trip to Florida, and was arrested several days later. In a post-arrest statement introduced at trial, Jackson admitted shooting Cole but claimed the shooting occurred accidentally during a struggle. He said the victim had attacked him with a knife when he resisted her sexual advances. He stated he had first fired warning shots into the ground and reloaded before the fatal shots. At trial he asserted self-defense or, alternatively, that intoxication had prevented him from forming the specific intent required for first-degree murder under Virginia law. The trial judge, sitting as factfinder, convicted Jackson of first-degree murder and sentenced him to thirty years in prison. Jackson's motion to set aside the judgment was denied. The Virginia Supreme Court denied his petition for a writ of error alleging insufficient evidence. Jackson then filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Virginia. The District Court applied the Thompson v. Louisville no-evidence standard and granted relief after finding insufficient proof of premeditation. The Court of Appeals for the Fourth Circuit reversed that judgment.
View caseMohan Malhotra bought a car from Meridian Motors that later malfunctioned. Meridian moved for judgment after the plaintiff's evidence because it believed the proof of defect was weak. The court denied the motion because the circumstances raised a jury question on whether the car was defective when sold.
In May 1955, Claus H. Henningsen purchased a new 1955 Plymouth Plaza Club Sedan from Bloomfield Motors, Inc., an authorized De Soto and Plymouth dealer for Chrysler Corporation. Mr. Henningsen intended the car as a Mother's Day gift for his wife, Helen Henningsen, and communicated that intention to the dealer. He alone signed a one-page printed purchase-order form. The reverse side contained, in fine six-point script type, a warranty clause limiting the manufacturer's obligation to replacement of defective parts within ninety days or four thousand miles and disclaiming all other warranties, express or implied. The front of the form contained two even smaller paragraphs directing attention to the back-side conditions. The form was a standardized document prepared by the manufacturer and used by all its dealers. No one called the fine-print provisions to Mr. Henningsen's attention, and he did not read them. The car was delivered on May 9, 1955, after the dealer performed the items listed in Chrysler's New Car Preparation Service Guide. On May 19, 1955, while Mrs. Henningsen was driving north on Route 36 in Highlands, New Jersey, at twenty to twenty-two miles per hour on a smooth, paved highway, she heard a loud noise from the front of the car. The steering wheel spun in her hands and the vehicle veered sharply into a highway sign and brick wall. The car had been driven only 468 miles, had required no servicing, and had exhibited no unusual behavior before the accident. An insurance appraiser with eleven years of experience examined the wrecked vehicle and concluded that something in the steering mechanism from the wheel down to the front wheels had broken or dropped off. Plaintiffs also presented expert testimony that the steering failure resulted from a latent manufacturing defect that could not have been discovered by reasonable inspection. The negligence counts against both defendants were dismissed at trial. The case was submitted to the jury solely on the implied-warranty claims. The jury returned verdicts for both plaintiffs against Chrysler Corporation and Bloomfield Motors, Inc. Defendants appealed and plaintiffs cross-appealed from the dismissal of the negligence claim. The Supreme Court of New Jersey certified the matter directly before consideration by the Appellate Division.
View caseMustafa Mahmoud sued Matrix Technologies alleging a conspiracy. Before the case went to the jury Matrix moved for judgment as a matter of law arguing the evidence lacked factual detail on agreement. The court denied the motion because the testimony gave a legally sufficient basis for a reasonable jury to find for the plaintiff.
The petitioners, Negro members of the Brotherhood of Railway and Steamship Clerks, brought this class suit in a Federal District Court in Texas on behalf of themselves and other Negro employees similarly situated. They sued the Brotherhood, its Local Union No. 28, and officers of both the Brotherhood and Local Union No. 28. The petitioners worked for the Texas and New Orleans Railroad at its Houston Freight House, where Local 28 acted as the designated bargaining agent for their unit under the Railway Labor Act. A contract between the Union and the Railroad protected employees in the unit from discharge and loss of seniority. In May 1954 the Railroad claimed to abolish 45 jobs held by the petitioners or other Negroes, leading to their discharge or demotion. The jobs were actually filled by white employees, although a few Negroes were rehired without their prior seniority. The Union, following a plan, ignored the petitioners' repeated requests for protection and declined to offer them the same safeguards provided to white employees. The complaint also asserted that the Union had failed overall to represent Negro employees equally and in good faith, seeking declaratory judgment, injunction, and damages for the alleged violation of fair representation rights under the Railway Labor Act. The respondents moved to dismiss the complaint, contending that the National Railroad Adjustment Board possessed exclusive jurisdiction, that the Railroad was an indispensable party not joined as a defendant, and that the complaint did not state a claim for relief. The District Court dismissed the action on the basis of the Adjustment Board's exclusive jurisdiction. The Court of Appeals for the Fifth Circuit affirmed that dismissal. The Supreme Court granted certiorari because the case presented an important question about employee rights under the Railway Labor Act.
View caseMiguel Mendoza was prosecuted for drug possession. Before the case was submitted to the jury the judge instructed on a statutory presumption linking presence in a car to possession. Miguel moved for judgment as a matter of law arguing the presumption violated due process. The court denied the motion because the presumption was rational on the facts presented.
In March 1973, three adult male respondents and a sixteen-year-old girl were traveling in a Chevrolet on the New York State Thruway when the car was stopped for speeding. Police observed two loaded handguns weighing approximately six pounds in an open handbag on the front floor or seat beside the girl, who admitted the bag belonged to her. A machinegun and heroin were discovered in the trunk after it was pried open. The four were tried together in Ulster County Court for possession of the handguns and trunk items. The trial judge instructed the jury regarding the statutory presumption that the presence of firearms in the automobile constituted evidence of possession by all occupants. The jury found the three adult males guilty of handgun possession but acquitted everyone of the trunk charges. The convictions were affirmed by the Appellate Division without opinion. The New York Court of Appeals also affirmed. The respondents sought federal habeas corpus relief in the Southern District of New York. The district court granted the writ on the ground that the presumption could not support the convictions on these facts. The Second Circuit affirmed the grant of the writ, though on the basis that the statute was unconstitutional on its face. The Supreme Court granted certiorari to consider the procedural and substantive issues raised by the lower federal courts' decisions.
View caseA 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 that entitle the movant to relief. The court may grant the motion if a reasonable jury would lack a legally sufficient evidentiary basis to find for the opposing party.
The court views the evidence in the light most favorable to the non-moving party and asks whether a rational jury could find for that party. The court does not weigh credibility or resolve factual disputes. If the evidence is legally insufficient the court must grant the motion.
Yes. An acquittal on the ground that the evidence is legally insufficient is a final determination on the merits that precludes reprosecution for the same offense. The bar applies even if the later charge is rephrased or brought under a different label.
No. The judge must assume the jury credited the evidence supporting the verdict. Reweighing credibility and entering judgment contrary to a supportable verdict violates the right to jury trial. The proper remedy is a new trial if the verdict is against the great weight of the evidence.
…as to the happening of the accident was not sufficient to demonstrate a breach of warranty. Consequently, they claim that their motion for judgment should have been granted by the trial court. We cannot agree. In our view, the total effect of the circumstances shown from purchase to accident is adequate to raise an inference that the…