Judgment Notwithstanding the Verdict (JNOV)
A post-verdict ruling that overturns a jury's verdict because no reasonable jury could have reached it.
JNOV is the traditional name for a motion asking the trial judge to enter judgment contrary to the jury's verdict on the ground that the evidence could not reasonably support it. In federal court the label has technically been retired: Federal Rule of Civil Procedure 50(b) calls it a renewed motion for judgment as a matter of law, because the movant must first have made an unsuccessful motion for judgment as a matter of law under Rule 50(a) before the case went to the jury. Many state courts still use JNOV as a matter of everyday vocabulary, so the two terms are generally treated as interchangeable in practice.
The standard is deliberately narrow. A judge ruling on the motion does not reweigh credibility or substitute her own view of the facts; she asks only whether the evidence, viewed in the light most favorable to the verdict winner, permits a reasonable jury to have reached that verdict at all. If reasonable minds could differ, the verdict stands even if the judge would have decided the case differently. That is what separates JNOV from a motion for a new trial, which can be granted on the broader ground that the verdict was against the weight of the evidence.
Because the underlying motion was already made and denied before verdict, JNOV is essentially the losing side's second chance to press the same legal-sufficiency argument after the jury has spoken. Courts often rule on a conditional new-trial motion at the same time, so that if an appellate court reverses the JNOV grant, there is already a fallback ruling in the record instead of a full remand for a fresh decision. Appellate review of a JNOV ruling is de novo, since it turns on a legal question rather than a discretionary call.
How it actually shows up
Trial counsel treat the Rule 50(a)/50(b) sequence as a mandatory checkpoint for preserving appellate rights, and insurers and in-house counsel watch it as a real (if narrow) chance to undo an adverse plaintiff's verdict without a full appeal. In a risk model it represents a distinct post-verdict branch: a small but non-zero probability that a favorable jury outcome gets reversed before judgment is ever entered.
- Is JNOV the same thing as a renewed motion for judgment as a matter of law?
- Functionally yes. Federal courts now call it a renewed motion for judgment as a matter of law under Rule 50(b), while many state courts still use the older term JNOV. Both describe a post-verdict motion asking the judge to enter judgment contrary to the jury because no reasonable jury could have reached that verdict.
- What do you have to do before you can file for JNOV?
- In federal court you must first move for judgment as a matter of law under Rule 50(a) before the case goes to the jury, and that motion must be denied or deferred. Skipping that step generally forfeits the right to renew the argument after verdict, which is why trial counsel treat it as a mandatory preservation step, not optional.
- How often is JNOV actually granted?
- Rarely. The standard requires the evidence to permit only one reasonable conclusion, contrary to what the jury found, so courts are reluctant to grant it absent a clear legal insufficiency. It is more often used to preserve issues for appeal than to actually overturn a verdict at the trial-court level.
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