Legal Memorandum: Motion for Judgment As a Matter of Law

Issue: What is the standard of review in the Fifth Circuit tc "Standards of Review " l 2for a ruling on a motion for a judgment as a matter of law?

A motion for judgment as a matter of law (formerly JNOV) may not be granted where "there is substantial evidence in the record raising a relevant fact issue for determination by the jury."  See Eyre v. McDonough Power Equip., Inc., 755 F.2d 416, 420 (5th Cir. 1985). 

The Fifth Circuit Court of Appeals reviews de novo the lower court’s ruling on a motion for judgment as a matter of law under Fed. R. Civ. P. 50(a).  Omnitech Int’l, Inc. v. Clorox Co., 11 F.3d 1316, 1322‑23 (5th Cir. 1994).  All evidence and reasonable inferences are viewed in favor of the non‑movant.  If reasonable persons could differ in their interpretation of the evidence, the motion should be denied. Only when the facts and the reasonable inferences are such that a reasonable juror could not reach a contrary verdict may the district court properly grant a motion for judgment as a matter of law.  See Texas Farm Bureau v. United States, 53 F.3d 120, 123 (5th Cir. 1995).

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