Legal Memorandum: Judgment as a Matter of Law Motion

Issue: What are the standards for deciding motions under Rule 50(b) and 59 in Minnesota?

Area of Law: Litigation & Procedure
Keywords: Judgment as a matter of law; Standard for deciding
Jurisdiction: Minnesota
Cited Cases: 538 F.3d 979; 332 F.3d 1150; 486 F.3d 418; 677 F.2d 681; 245 F.3d 1008; 766 F.2d 378; 760 F.2d 864
Cited Statutes: Fed. R. Civ. P. 50(a)(1); Rule 50(b) and 59
Date: 08/01/2013

Judgment as a Matter of Law (JMOL) should be granted only if there is "No Proof Beyond Speculation to Support the Verdict".  Succinctly stated, the standard for deciding a motion for JMOL is:

[JMOL] is warranted when no "legally sufficient evidentiary basis" exists for a reasonable jury to have found in favor of a party on an issue on which the party has been fully heard. . . .  [JMOL] is appropriate only when all the evidence points in one direction and there are no reasonable interpretations that would support the jury’s verdict.


Dominium Mgmt. Servs., Inc. v. Nationwide Hous. Group., 195 F.3d 358, 363 (8th Cir. 1999) (quoting Fed. R. Civ. P. 50(a)(1)) (other citations omitted).  (Dominium Management also discusses the standard for a new-trial motion.  See § II.B below.)

The moving party has a "heavy burden" on a JMOL motion.  Gill v. Maciejewski, 546 F.3d 557, 562 (8th Cir. 2008).  In Gill, the court stated:

"[JMOL] is appropriate only when the nonmoving party fails to present enough evidence to permit a reasonable jury to decide in his favor."  The nonmoving party must present more than a "mere scintilla" of evidence . . . and we are required to view the evidence in the light most favorable to the nonmoving party.

Id. (citations omitted).  In Gill, an excessive-force case, a patron at Sally’s Saloon near the University of Minnesota was ejected from the bar after being involved in an altercation in the men’s room.  […]

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