civil procedure · procedure

Elements of Judgment Notwithstanding Verdict

Quick Answer

What are the elements of Judgment Notwithstanding Verdict?

A Judgment Notwithstanding the Verdict (JNOV) is a judicial ruling that nullifies the jury's decision when the judge believes that no reasonable jury could have reached the same conclusion based on the evidence presented. It is typically sought after a jury trial and can only be granted when one party believes the verdict lacks a legally sufficient evidentiary basis.

Required Elements

1. Jury Verdict

A specific verdict rendered by the jury in the case must exist, typically reflecting a resolution of the issues presented.

What to prove: The jury reached a verdict that is contrary to the evidence or law applicable in the case.

2. Sufficiency of Evidence

The evidence presented at trial must be analyzed to determine if it coherently supports the claimed verdict.

What to prove: The moving party must demonstrate that, viewing all evidence in the light most favorable to the non-moving party, there is insufficient evidence to support the jury's verdict.

3. Legal Standards

The court must apply the correct legal standards that govern the claims in the case.

What to prove: The JNOV applicant must show that the jury's verdict is inconsistent with the applicable legal standards or misapplication of law.

Burden of Proof

The burden of proof lies with the party moving for JNOV, and the standard is typically 'clear and convincing evidence' or 'beyond a reasonable doubt' depending on jurisdiction.

Common Fact Patterns
  • A jury rules in favor of a plaintiff despite overwhelming evidence indicating that the defendant acted reasonably.
  • A jury awards a substantial sum in damages despite a complete lack of evidence to support the amount claimed.
Exam Tip

In exams, focus on the interplay between jury findings and legal standards when discussing JNOV. Be prepared to evaluate scenarios where evidence may lead to a JNOV.

Key Cases
  • Harris v. Forklift Systems, Inc.
  • Judicial Watch, Inc. v. National Energy Policy Development Group
  • Reeves v. Sanderson Plumbing Products, Inc.

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