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A grocer from State A filed a diversity action against a supplier from State B in federal court in State B, seeking $195,000 in damages arising from a contract dispute. Both sides presented conflicting evidence as to whether there was a valid contract. During the course of the trial, the grocer's attorney submitted a motion for judgment as a matter of law, which the court denied. After the jury returned a verdict for the grocer in the amount of $1,500, the grocer submitted a renewed motion for judgment as a matter of law and an alternative motion for a new trial.
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FRCP 50 states, in ruling on the renewed motion, the court may:
(i) allow judgment on the verdict if the jury returned a verdict;
(ii) order a new trial; OR
(iii) direct the entry of judgment as a matter of law.
Motions for judgment as a matter of law and motions for a new trial have different requirements, so circumstances may justify a court granting the latter but not the former. A motion for judgment as a matter of law is brought only after the nonmoving party has been fully heard on the matter. The court will grant this motion if it finds that a reasonable jury would not have a legally sufficient basis to find for the party on that issue.
A motion for a new trial, on the other hand, is granted because of an error during trial, because the verdict is against the weight of the evidence, because of juror misconduct, or because the verdict is inadequate. Therefore, there might be sufficient evidence for a judge to deny a motion for judgment as a matter of law on the ground that a reasonable jury could find for the other party, yet a judge could grant a motion for a new trial if she thought the jury's verdict was deeply flawed.
C is correct. The court is likely to grant the motion for a new trial but reject the motion for judgment as a matter of law because the requirements are more easily satisfied for the new trial. The jury found for the grocer, but only awarded $1,500 in damages when the original amount sought was $195,000.
This is more likely than granting the motion for judgment as a matter of law, which will be granted if a reasonable jury would not have a legally sufficient basis to find for the party on that issue. The jury found for the grocer, so that's not the issue. The issue is that the damages verdict is inadequate.
A is incorrect. The fact that the jury technically found for the grocer does not mean a motion for judgment as a matter of law may not be brought where the verdict returns substantially less than what the grocer sought. Here, the grocer sought $195,000 in damages and was awarded $1,500.
B is incorrect. The fact that the jury found for the grocer does not mean that a motion for a new trial may not be brought where, as here, the verdict returns substantially less than what the grocer sought.
D is incorrect. A motion for a new trial may be granted where the verdict is against the weight of the evidence, i.e., even when the party against whom the motion is granted had some evidence to support her claim. As stated above, a motion for a judgment as a matter of law and a motion for a new trial have different requirements because the motion for judgment as a matter of law is appropriate when a reasonable jury did not have a legally sufficient basis to find for the winning party. Here, the winning party is the grocer, who is contesting the sufficiency of the verdict.