Motion for JNOV / Directed Verdict — Rule 50

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01ATTORNEY INFORMATION

Attorney Name *

State Bar No. *

Firm / Office Name

Address *

Phone *

Fax

Email *

02CASE INFORMATION

County *

File No. *

Division

Moving Party's Role *

Moving Party Name *

Opposing Party Name *

Verdict Date *

JNOV Deadline (10 days from verdict)

03TYPE OF MOTION

CRITICAL DEADLINES:
Directed Verdict: Must be moved at close of all evidence, before the case is submitted to the jury.
JNOV (Rule 50(b)): Must be filed within 10 days of entry of judgment — no exceptions.

Motion Type *

JNOV (Rule 50(b)): Motion filed after entry of judgment, renewing a directed verdict motion made at close of evidence. The directed verdict motion at trial is a prerequisite.

04VERDICT / EVIDENCE AT ISSUE

What Did the Jury Find? *

What Evidence Is Claimed Insufficient? *

05GROUNDS

No evidence supporting the verdict — the claim should not have been submitted to the jury Evidence is so one-sided that reasonable persons could not differ — reasonable minds cannot disagree that moving party is entitled to judgment Verdict is against the greater weight of the evidence (in the alternative — motion for new trial under Rule 59)

06ALTERNATIVE MOTION FOR NEW TRIAL

In the alternative, Moving Party moves for a new trial pursuant to N.C.R. Civ. P. Rule 59, on the grounds that the verdict is against the greater weight of the evidence and/or for other grounds set forth below.

Additional Grounds for New Trial (optional)

07ARGUMENT

Argument in Support of Motion *

08CERTIFICATE OF SERVICE

Date Served *

Served Upon *

10-DAY DEADLINE
JNOV must be filed within 10 days of entry of judgment. Calendar the deadline immediately after verdict.

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RULE 50 CHECKLIST

Directed verdict: Move at the close of evidence before submission to jury — this is a prerequisite to JNOV
JNOV: File within 10 days of entry of judgment — courts have no discretion to extend this
Standard: Whether, viewing evidence in the light most favorable to non-movant, reasonable persons could not differ on the verdict
File JNOV and Rule 59 new trial motion simultaneously — they are different standards and both should be preserved
JNOV preserves the right to appeal denial without waiting for new trial ruling
A party who did not move for directed verdict at trial cannot obtain JNOV

STATUTORY REFERENCE

Rule 50(a)Directed verdict (at close of evidence)

Rule 50(b)JNOV — within 10 days of judgment

Rule 59Motion for new trial

Rule 59(a)(7)Verdict contrary to evidence

Dickinson v. Pake284 N.C. 576 (1974)

Bryant v. Nationwide313 N.C. 362 (1985)

NEED AN ATTORNEY?

This motion must be filed and signed by a licensed NC attorney
Barker Richardson, PLLC → for civil litigation