jnov-motion
Drafts a Motion for Judgment Notwithstanding the Verdict (JNOV) under FRCP 50(b) or state equivalents, with alternative new-trial request. Builds element-by-element evidentiary insufficiency arguments using transcript citations and preserves the appellate record. Use when drafting JNOV motions, p...
Full skill instructions
Drafts a post-trial motion showing no reasonable jury could have reached the verdict, with an alternative new-trial request preserving appellate review.
Collect before drafting:
Caption, numbered paragraphs, Bluebook citations (unless local rules differ), signature block, proposed order.
| Section | Content |
|---|---|
| Caption | Title: "Motion for Judgment Notwithstanding the Verdict, or in the Alternative, for a New Trial" |
| Notice of Motion | Hearing date/manner per local rules; governing procedural rule |
| Introduction | Moving party, verdict date, claims challenged, Rule 50(a) reference, 2-3 sentence thesis |
| Background | Case history → trial proceedings → evidence with transcript cites (e.g., "Tr. 145:12-18") → verdict → prior directed verdict motions |
| Legal Standard | Controlling circuit/state authority; distinguish JNOV from new-trial standard |
| JNOV Argument | Element-by-element insufficiency (see template below) |
| New Trial Alternative | Trial errors + against-the-weight arguments (see template below) |
| Conclusion | Specific relief; alternative relief; costs; stay of execution if appropriate |
| Proposed Order | Separate signature-ready order for JNOV or, alternatively, new trial |
For each element the non-movant bore the burden to prove:
[Claim Name]: [Element]
Legal requirement: [Element definition + burden of proof]
Evidence presented: [Non-movant's best evidence, viewed favorably to them, with Tr. cites]
Why insufficient:
- [Gap: e.g., no expert testimony on causation where required]
- [Gap: e.g., damages testimony speculative/conclusory]
- [Gap: e.g., no documentary support for alleged agreement]
Supporting authority: [Cases granting JNOV on analogous records]
Alternative Ground [N]: [Error Type]
The error: [What happened, with Tr./Dkt. cites]
Preservation: [Objection at Tr. ___]
Prejudice: [Effect on verdict — not harmless because ___]
Organize by category:
| Issue | Consequence |
|---|---|
| No prior Rule 50(a) motion at trial | JNOV generally unavailable — flag if preservation is uncertain |
| Missing deadline (28 days federal) | Motion forfeited — flag deadline prominently in filing |
| Arguing credibility | Impermissible on JNOV — focus on absence of evidence, not witness believability |
| Ignoring partial relief | Courts more likely to grant JNOV on specific claims or damage components than entire verdict |
| Conflating standards | JNOV = "no reasonable jury"; new trial = "great weight of evidence" (more lenient) — keep arguments distinct |
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