Judgment Notwithstanding the Verdict vs Summary Judgment in Law - What is The Difference?

Last Updated Feb 2, 2025

Summary judgment allows a court to decide a case without a full trial when there are no material facts in dispute. This legal tool speeds up the resolution process, saving time and resources for both parties involved. Explore the article to understand how summary judgment might impact Your case outcomes.

Table of Comparison

Aspect Summary Judgment Judgment Notwithstanding the Verdict (JNOV)
Definition Decision by the court without a full trial, based on undisputed facts. Court overturns jury's verdict due to insufficient legal basis.
Timing Before or during trial, typically after discovery. After jury verdict is rendered.
Purpose To avoid unnecessary trial when facts are clear. To correct a jury decision unsupported by law or evidence.
Legal Standard No genuine dispute of material fact exists. Reasonable people could not have reached that verdict.
Decision Maker Judge only. Judge overrides jury.
Result Case resolved without trial or further proceedings. Jury verdict set aside; judgment entered for opposing party.
Applicable In Civil cases with clear facts and law. Civil cases where jury verdict lacks legal support.

Introduction to Summary Judgment and JNOV

Summary judgment is a legal procedure that allows a court to promptly resolve a case without a full trial when there are no genuine disputes over material facts, ensuring efficient judicial process. Judgment Notwithstanding the Verdict (JNOV) occurs after a jury's decision, enabling the court to overturn the verdict if it finds that no reasonable jury could have reached that conclusion based on the evidence. Both mechanisms serve as critical tools to prevent unnecessary trials or enforce legal correctness in court rulings.

Definitions: Summary Judgment vs JNOV

Summary Judgment is a legal ruling made by a court without a full trial, asserting that there are no genuine disputes over material facts and the moving party is entitled to judgment as a matter of law. Judgment Notwithstanding the Verdict (JNOV) occurs after a jury trial and allows the judge to overturn the jury's verdict if the judge finds that no reasonable jury could have reached that decision based on the evidence. Both remedies serve to resolve cases efficiently but differ in timing and procedural context, with Summary Judgment occurring pre-trial and JNOV post-verdict.

Legal Standards for Summary Judgment

Summary judgment is granted when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law, effectively bypassing a trial. The legal standard for summary judgment requires the court to view the evidence in the light most favorable to the non-moving party and determine if reasonable minds could differ. Judgment notwithstanding the verdict (JNOV) occurs post-trial, allowing the court to reverse the jury's decision if it finds that no reasonable jury could have reached the verdict based on the evidence presented.

Legal Standards for Judgment Notwithstanding the Verdict (JNOV)

Judgment Notwithstanding the Verdict (JNOV) requires the court to find that no reasonable jury could have reached the given verdict based on the evidence presented, effectively overriding the jury's decision. The legal standard mandates that the evidence, viewed in the light most favorable to the non-moving party, must be insufficient to support the verdict, warranting judgment as a matter of law. Courts apply this stringent standard to ensure that JNOV is only granted when the verdict defies clear legal principles or lacks evidentiary basis, distinguishing it from summary judgment which occurs before trial.

Timing: When Each Motion is Applicable

Summary judgment is typically filed before trial, aiming to resolve the case when there are no genuine disputes of material fact, allowing the court to decide based on the law alone. Judgment Notwithstanding the Verdict (JNOV) is filed after a jury verdict, challenging the sufficiency of evidence to support the jury's decision and requesting the court to overturn or amend that verdict. The timing difference is crucial: summary judgment prevents trial by addressing legal issues upfront, while JNOV acts as a post-trial remedy to correct potential errors in jury findings.

Procedural Differences Between Summary Judgment and JNOV

Summary judgment is granted before trial when the court determines no genuine dispute of material fact exists, allowing the case to be decided as a matter of law. Judgment notwithstanding the verdict (JNOV) occurs after a jury trial, enabling the court to override the jury's verdict if it finds that no reasonable jury could have reached that decision based on the evidence. Procedurally, summary judgment aims to avoid unnecessary trials, while JNOV corrects legally insufficient jury verdicts post-trial.

Burden of Proof in Both Motions

Summary Judgment requires the moving party to demonstrate that there is no genuine dispute of material fact and that they are entitled to judgment as a matter of law, effectively shifting the burden of proof early in the litigation process. Judgment Notwithstanding the Verdict (JNOV) occurs after a jury verdict, where the moving party must show that no reasonable jury could have reached the given verdict based on the evidence presented, placing a higher burden to prove the insufficiency of the opposing party's evidence. Both motions address the burdens related to the sufficiency of evidence but operate at different procedural stages, with Summary Judgment focusing on pre-trial evidentiary standards and JNOV challenging the verdict's reasonableness post-trial.

Impact on Trial Proceedings

Summary judgment accelerates trial proceedings by resolving disputes without a full trial when there is no genuine issue of material fact, thereby saving resources and time. Judgment notwithstanding the verdict (JNOV) occurs post-trial, allowing a judge to overturn the jury's verdict if it contradicts the law or evidence, potentially altering the trial outcome. Both mechanisms significantly influence judicial efficiency but operate at different stages, impacting trial duration and finality.

Appellate Review of Summary Judgment and JNOV

Summary judgment is reviewed on appeal under a de novo standard, meaning appellate courts independently assess whether genuine issues of material fact exist without deferring to the trial court's conclusions. Judgment notwithstanding the verdict (JNOV) undergoes similar de novo appellate review, with courts examining whether reasonable jurors could have reached the verdict based on evidence presented. Both appeals focus on legal sufficiency, but summary judgment review occurs pre-trial, while JNOV review addresses post-verdict challenges to jury findings.

Key Case Law Illustrating Both Concepts

Summary judgment, grounded in Celotex Corp. v. Catrett, 477 U.S. 317 (1986), resolves cases without trial when no genuine dispute of material fact exists, emphasizing judicial efficiency. Judgment notwithstanding the verdict (JNOV), exemplified in Gasperini v. Center for Humanities, Inc., 518 U.S. 415 (1996), permits a judge to overturn a jury's verdict if it lacks a legally sufficient evidentiary basis. These doctrines highlight distinct procedural mechanisms that courts utilize to ensure legal standards prevail beyond jury findings.

Summary Judgment Infographic

Judgment Notwithstanding the Verdict vs Summary Judgment in Law - What is The Difference?


About the author. JK Torgesen is a seasoned author renowned for distilling complex and trending concepts into clear, accessible language for readers of all backgrounds. With years of experience as a writer and educator, Torgesen has developed a reputation for making challenging topics understandable and engaging.

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