In US Federal Courts, Federal Rule of Civil Procedure 50 (FRCP 50) governs the process for Judgment as a Matter of Law (JMOL). This essential rule allows a court to remove a case or a specific issue from jury consideration if there is insufficient evidence to support a verdict. Understanding the two-stage process—Rule 50(a) and the renewed 50(b) motion—is critical for preserving appellate rights and challenging a jury verdict based on a lack of legally sufficient evidence.
In the high-stakes environment of a jury trial, sometimes the evidence presented by one party simply fails to meet the legal standard required to prove their claim. In these moments, a party can request a decisive intervention from the court: a Judgment as a Matter of Law (JMOL). Governed by Rule 50 of the Federal Rules of Civil Procedure (FRCP), JMOL is a critical mechanism that allows the court to take a case away from the jury—or nullify a jury’s verdict—when no reasonable jury could legally find for the non-moving party.
This powerful motion, formerly known as a ‘directed verdict’ (pre-verdict) or ‘judgment notwithstanding the verdict’ (JNOV) (post-verdict), ensures that cases built on legally insufficient evidence do not proceed to or stand after a verdict. For any litigation-focused Legal Expert, mastering the timing, substance, and procedural requirements of Rule 50 is non-negotiable for preserving a challenge to the sufficiency of evidence on appeal.
Rule 50 establishes a crucial two-step process that mandates action during the trial to preserve a party’s right to challenge the jury’s verdict after the trial. Failure to comply with the first stage, Rule 50(a), acts as an irredeemable procedural bar to the second, more powerful stage, Rule 50(b).
A Rule 50(a) motion for JMOL is the first opportunity for a party to challenge the legal sufficiency of their opponent’s evidence. It can be made once a party has been fully heard on an issue during a jury trial, but before the case is submitted to the jury.
The motion must be specific, detailing both the judgment sought and the specific law and facts that entitle the movant to that judgment. This specificity is vital because it alerts the court and the opposing party to the claimed evidentiary deficiency, offering the opposing party an opportunity to potentially cure the defect before the case concludes.
If the court denies the Rule 50(a) motion, the case proceeds to the jury. The denial of the 50(a) motion is considered conditional, meaning the court has submitted the action to the jury subject to its later decision on the legal questions raised by the motion.
If the jury returns a verdict against the movant, that party may file a renewed motion for judgment as a matter of law (RJMOL) under Rule 50(b). This renewed motion must be filed no later than 28 days after the entry of judgment.
Procedural Pitfall: The Renewal Rule
A Rule 50(b) motion must strictly be a renewal of the issues raised in the pre-verdict Rule 50(a) motion. Any argument concerning the sufficiency of the evidence not raised in the 50(a) motion is generally deemed waived and cannot be raised in the post-trial 50(b) motion, nor on appeal. This emphasizes why the 50(a) motion, even if expected to be denied, is so crucial.
The standard for granting a JMOL motion—whether under 50(a) or 50(b)—is rigorous and consistent: The court must find that a reasonable jury would not have a legally sufficient evidentiary basis to find for the non-moving party on that issue.
In essence, the motion is granted only when a case is wholly devoid of the kind of evidence that would permit a rational fact-finder to reach a conclusion in favor of the party opposing the motion. The court does not substitute its own judgment for that of the jury. It strictly examines the legal sufficiency of the evidence, not the weight or credibility.
In ruling on a 50(b) motion, the court must:
A JMOL is a directed verdict; the standard is “steep,” and a verdict will only be set aside if “no rational jury” could have rendered it.
When filing a renewed JMOL motion under Rule 50(b), it is common practice for a Legal Expert to simultaneously or alternatively file a motion for a new trial under Rule 59. While JMOL asserts a complete failure of proof, a Rule 59 motion argues that the verdict is merely against the “great weight of the evidence,” or that some error occurred during the trial that requires a new proceeding.
If the court grants the renewed Rule 50(b) motion, it must also issue a conditional ruling on the Rule 59 motion for a new trial. This conditional ruling determines whether a new trial should be granted if the court’s JMOL judgment is later vacated or reversed on appeal. This procedure is designed to provide guidance to the appellate court and prevent unnecessary remands.
| Motion | Rule | Standard |
|---|---|---|
| Judgment as a Matter of Law (Renewed) | FRCP 50(b) | No legally sufficient evidentiary basis for a reasonable jury to find for the opponent. |
| Motion for a New Trial | FRCP 59 | Verdict is against the great weight of the evidence, or a prejudicial error occurred. |
Rule 50 is more than a legal Hail Mary; it is a foundational pillar of trial practice that preserves a party’s right to appeal an adverse verdict on the grounds of evidentiary sufficiency. For litigation teams, overlooking the Rule 50(a) motion can be a fatal mistake, resulting in the complete waiver of the strongest post-verdict argument.
Rule 50, Judgment as a Matter of Law (JMOL), provides a mechanism in federal jury trials to test the foundational legal sufficiency of the evidence. It ensures that a jury is not permitted to base its verdict on conjecture or evidence that is legally inadequate to support a claim or defense. The key is the procedural link: a 50(a) motion made during trial is the non-negotiable gateway to a 50(b) renewed motion after the verdict. This two-step process is the primary tool for preserving the sufficiency-of-the-evidence argument for appellate review, a distinction that every successful Legal Expert must appreciate.
A motion for summary judgment (Rule 56) is made before trial, arguing that there is no genuine dispute of material fact. A Rule 50 JMOL motion is made during or after trial, arguing that a party has failed to meet its burden of production with the evidence actually presented to the jury.
If the 50(a) motion is denied, the case is submitted to the jury. The court is deemed to have reserved the right to later decide the legal question. If the jury returns an adverse verdict, the movant can then file a Renewed Motion for JMOL under Rule 50(b).
Yes, if the appellate court reverses the judgment, it has the authority to order a new trial, direct the trial court to consider a new trial, or direct the entry of judgment as a matter of law for the appellant, consistent with Rule 50(e).
Generally, yes. The 50(b) motion must be a renewal of the 50(a) motion. Any argument concerning the insufficiency of the evidence not raised with specificity in the 50(a) motion is considered waived for the 50(b) motion and appeal.
This article is for informational purposes only and does not constitute legal advice. Rules of Civil Procedure are subject to change and local judicial interpretation. Always consult with a qualified Legal Expert regarding your specific jurisdiction and case. This content was generated by an AI model and should be reviewed for current accuracy.
Rule 50, Judgment as a Matter of Law, JMOL, FRCP 50, Renewed JMOL, RJMOL, directed verdict, insufficient evidence, jury trial motion, preserve appeal, post-trial motion, civil procedure
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