Also known as: motions for judgment as a matter of law · judgment as a matter of law · JMOL · Rule 50 motion
Written by attorneys — see sources below.
A procedural device by which a court enters judgment when a party has been fully heard on an issue and the record supplies no legally sufficient evidentiary basis for a reasonable jury to find for that party.
Mustafa Mahmoud sued Mercury Industries after a company van struck his vehicle. He offered only his own testimony and photos of the scene. Mercury Industries moved for judgment as a matter of law after Mahmoud rested. The court granted the motion because no evidence permitted a reasonable jury to find negligence.
Maria Morales sued Matrix Technologies for breach of a supply contract. After both parties presented evidence and rested, Matrix Technologies moved for judgment as a matter of law on the damages claim. The motion specified the judgment sought and the facts showing insufficient proof. The court considered the motion before submitting the case to the jury.
Matthew Martinez sued Monarch Pharmaceuticals for unpaid change orders. After Martinez rested, Monarch moved for judgment as a matter of law on the ground that no written notices had been sent. Martinez offered no contrary evidence. The court granted the motion because the record supplied no legally sufficient basis for a reasonable jury to find for Martinez.
Miguel Mendoza sued Meridian Motors for patent infringement. The jury found infringement, but Meridian Motors renewed its motion for judgment as a matter of law. The court granted the motion after construing the patent claims as a matter of law. The ruling removed the issue from the jury despite the verdict.
Maurice Marshall sued Mercury Industries for personal injuries. The jury returned a verdict for Marshall. Mercury Industries renewed its motion for judgment as a matter of law under Rule 50(b). The court considered whether the evidence supported the verdict before deciding the motion.
William Gasperini, a journalist and photographer who had taken over 5,000 slide transparencies while reporting in Central America, agreed in 1990 to supply 300 of his original color transparencies to The Center for Humanities, Inc., for use in an educational videotape titled Conflict in Central America. After the project concluded, the Center could not locate or return the transparencies, prompting Gasperini to pursue legal remedies for their loss. Gasperini, a California citizen, sued the Center, a New York corporation with its principal place of business in New York, in the United States District Court for the Southern District of New York. He invoked diversity jurisdiction under 28 U.S.C. § 1332 and alleged state-law claims for breach of contract, conversion, and negligence. The Center conceded liability, so the case proceeded to trial solely on damages. At the three-day jury trial, Gasperini's expert testified that the industry standard valued each lost transparency at $1,500 as the average license fee over the photographer's copyright term. Gasperini testified that his photography earnings from 1984 through 1993 totaled just over $10,000 and that he planned to publish a book of his best Central American photographs. The jury returned a verdict of $450,000, or $1,500 for each of the 300 slides. The Center moved for a new trial under Federal Rule of Civil Procedure 59, invoking both the federal standard and New York Civil Practice Law and Rules § 5501(c). The District Court denied the motion without comment. The Court of Appeals for the Second Circuit vacated the judgment after applying the New York deviates-materially standard itself. The Second Circuit surveyed Appellate Division decisions on similar awards and concluded that the verdict materially deviated from reasonable compensation because many slides were generic and Gasperini had limited earnings. It ordered a new trial unless Gasperini accepted a reduction to $100,000. The Supreme Court granted certiorari to resolve the conflict over the proper standard.
View caseMichael Miller sued Matrix Technologies after a product allegedly caused his injury. After Miller rested, Matrix moved for judgment as a matter of law supported by uncontradicted expert evidence showing no causal link. Miller offered no opposing proof. The court granted the motion because the record supplied no legally sufficient basis for a reasonable jury to find for Miller.
A party may move once the opposing party has been fully heard on the issue. The motion may be made at any time before the case is submitted to the jury. The motion must specify the judgment sought and the supporting law and facts.
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The court grants the motion when the record contains no legally sufficient evidentiary basis for a reasonable jury to find for the nonmoving party. Speculative or conclusory evidence alone does not meet this standard.
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No. The rule permits the motion once the opposing party has rested its case on the issue. The movant need not introduce evidence first.
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The court is treated as having submitted the action to the jury. The movant may renew the motion under Rule 50(b) after the verdict.
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The motion for judgment as a matter of law is made during or after trial on the sufficiency of evidence actually admitted. Summary judgment is decided before trial on the absence of a genuine dispute of material fact.
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…damages, 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…