FRCP/Judgments

Rule 50: Judgment as a Matter of Law (JMOL)

Quick Answer

What is Judgment as a Matter of Law (JMOL)?

Judgment as a matter of law is the mechanism by which a court can override a jury verdict — or prevent one from being rendered — when the evidence so clearly favors one side that no reasonable jury could find otherwise. It raises fundamental questions about the relationship between judges and juries.

Source: Fed. R. Civ. P. 50

Plain English Explanation

Judgment as a matter of law is the mechanism by which a court can override a jury verdict — or prevent one from being rendered — when the evidence so clearly favors one side that no reasonable jury could find otherwise. It raises fundamental questions about the relationship between judges and juries.

The process works in two stages. First, during trial, a party makes a Rule 50(a) motion (formerly called a directed verdict) arguing that the evidence is legally insufficient. If the court denies the motion and the jury returns a verdict, the losing party can renew the motion under Rule 50(b) (formerly called JNOV — judgment notwithstanding the verdict) within 28 days of judgment. Making the 50(a) motion during trial is an absolute prerequisite to filing a 50(b) motion — you cannot skip step one.

The standard is the same at both stages: could a reasonable jury, viewing the evidence in the light most favorable to the nonmoving party, have reached the verdict? If no reasonable jury could have, judgment as a matter of law is appropriate. This standard respects the Seventh Amendment's protection of the jury right while ensuring that verdicts are grounded in evidence.

Key Points

  1. 150(a) motion (directed verdict) must be made before the case goes to the jury — this is a prerequisite to 50(b)
  2. 250(b) motion (JNOV) must be filed within 28 days after entry of judgment
  3. 3Standard: no reasonable jury could find for the nonmoving party on a legally sufficient evidentiary basis
  4. 4Evidence viewed in the light most favorable to the nonmoving party
  5. 5May be combined with a Rule 59 motion for a new trial

Common Exam Issues

  • Failure to make a 50(a) motion and its effect on the right to file a 50(b) motion
  • The standard for granting JMOL and its relationship to the Seventh Amendment
  • The 28-day deadline for filing a 50(b) motion
  • Combining a 50(b) motion with a Rule 59 new trial motion

Important Cases

Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000)

Weisgram v. Marley Co., 528 U.S. 440 (2000)

Unitherm Food Systems, Inc. v. Swift-Eckrich, Inc., 546 U.S. 394 (2006)

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