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

Last Updated Feb 2, 2025

Judgment Notwithstanding the Verdict (JNOV) allows a judge to overturn the jury's decision if it appears that no reasonable jury could have reached that verdict based on the evidence presented. This legal tool serves as a critical check to ensure that justice is upheld even when jury findings seem flawed or unsupported. Discover how JNOV might impact your case by exploring the detailed insights in the rest of this article.

Table of Comparison

Aspect Judgment Notwithstanding the Verdict (JNOV) Special Verdict
Definition Judicial decision overriding the jury's verdict. Verdict where the jury states factual findings without applying the law.
Purpose Correct errors when jury's verdict lacks legal basis. Clarify facts for judge to apply the law.
Application Stage Post-verdict, during judgment phase. During or after jury deliberation on facts.
Decision Maker Judge alone. Jury provides factual determinations; judge applies law.
Effect Overrules jury's verdict, can change outcome. Facilitates judge's legal decision-making based on jury facts.
Legal Standards Verdict must be unsupported by any reasonable evidence. Jury must identify specific facts without stating legal conclusions.
Common Use Civil and criminal cases to challenge improper jury verdicts. Complex factual cases needing clear jury fact-finding.

Introduction to Judicial Verdicts

Judgment Notwithstanding the Verdict (JNOV) allows a judge to override a jury's decision when legally insufficient evidence supports it, ensuring correct application of the law. Special Verdict involves the jury making specific factual determinations, which the judge uses to apply the law and render the final judgment. Both mechanisms maintain judicial oversight and accuracy in trial verdicts by balancing jury findings with legal standards.

Defining Judgment Notwithstanding the Verdict (JNOV)

Judgment Notwithstanding the Verdict (JNOV) is a legal remedy allowing a court to override a jury's verdict when no reasonable jury could have reached that conclusion based on the evidence presented. It effectively reverses the jury's decision and enters judgment in favor of the opposing party, often used in civil cases to correct errors or prevent unjust outcomes. Unlike a Special Verdict, which reflects the jury's specific factual findings, JNOV challenges the legal sufficiency of the verdict itself.

Understanding Special Verdicts

Special verdicts require the jury to find specific facts based on evidence rather than deliver a general judgment, providing a clear legal framework for the court to apply the law. This process helps judges handle complex cases by separating factual determinations from legal conclusions, enhancing precision in verdict outcomes. Understanding special verdicts clarifies their role in guiding judicial decisions, contrasting with a judgment notwithstanding the verdict, where judges may override or modify a jury's general verdict based on legal grounds.

Key Differences Between JNOV and Special Verdict

Judgment Notwithstanding the Verdict (JNOV) allows a judge to overturn the jury's decision when the evidence overwhelmingly supports the losing party, whereas a Special Verdict requires the jury to answer specific factual questions which guide the judge's final ruling. JNOV directly challenges the jury's conclusion by entering a judgment contrary to the verdict, while a Special Verdict clarifies the factual basis without immediately deciding the case outcome. The key difference lies in JNOV's role as a post-verdict judicial override versus Special Verdict's function as a detailed factual determination to assist judicial decision-making.

Legal Basis for Judgment Notwithstanding the Verdict

The legal basis for Judgment Notwithstanding the Verdict (JNOV) lies in Rule 50(b) of the Federal Rules of Civil Procedure, allowing a judge to override a jury's verdict if no reasonable jury could have reached that conclusion based on the evidence. It serves as a safeguard against erroneous jury decisions that contradict the law or lack sufficient evidentiary support. In contrast, a Special Verdict involves the jury making explicit findings on specific factual issues, leaving the judge to apply the law accordingly without questioning the jury's factual determinations.

Procedures for Requesting Special Verdicts

Requesting a special verdict requires a party to submit specific written questions to the court that the jury must answer based on evidence presented, ensuring clarity on factual issues rather than overall liability or damages. This procedure allows the court to review the jury's detailed findings before forming a final judgment, contrasting with a Judgment Notwithstanding the Verdict, which challenges the legal sufficiency of the jury's overall decision after verdict submission. Properly timed motions and compliance with jurisdictional rules regarding special verdict requests are critical to preserve a party's right to challenge or clarify jury determinations.

Advantages and Drawbacks of JNOV

Judgment Notwithstanding the Verdict (JNOV) allows a judge to overturn a jury's decision when the evidence clearly does not support the verdict, providing a crucial safeguard against erroneous jury findings. However, JNOV may undermine the jury's role as the primary fact-finder, potentially leading to judicial overreach and diminishing the perceived fairness of trial outcomes. The advantage of JNOV lies in correcting manifest errors, but its drawback includes the risk of subjective judicial interference that can prolong litigation and increase appellate review.

Practical Implications of Special Verdicts

Special verdicts require the jury to find facts separately rather than deliver a general verdict, allowing judges to apply legal standards more precisely during judgment. This method reduces ambiguity in jury decisions, facilitating clearer appellate review and minimizing grounds for post-trial motions such as Judgment Notwithstanding the Verdict (JNOV). In practice, special verdicts enhance judicial efficiency by providing detailed factual findings, which help courts avoid overstepping jury functions while ensuring legal correctness in final rulings.

Notable Cases Illustrating JNOV vs Special Verdict

In notable cases such as Gasoline Products Co. v. Champlin Refining Co., the U.S. Supreme Court highlighted the proper use of Judgment Notwithstanding the Verdict (JNOV) to overturn jury decisions lacking sufficient evidence. Conversely, in Sullivan v. Crabtree, courts emphasized the special verdict's role in clarifying specific factual findings, allowing judges to render final decisions based on those facts. These cases illustrate the distinct judicial functions of JNOV and special verdicts in ensuring accurate and legally sound trial outcomes.

Conclusion: Choosing Between JNOV and Special Verdict

Choosing between a Judgment Notwithstanding the Verdict (JNOV) and a Special Verdict depends on the desired legal outcome and procedural considerations; JNOV overturns a jury's verdict when no reasonable jury could have reached that conclusion, effectively substituting the judge's decision for the jury's. A Special Verdict requires the jury to answer specific factual questions, allowing the judge to apply the law based on those findings, which can limit jury discretion and provide clearer grounds for judgment. Strategic use of JNOV or Special Verdict hinges on the strength of the evidence, the complexity of factual issues, and the need for judicial intervention versus deference to the jury's role.

Judgment Notwithstanding the Verdict Infographic

Special Verdict vs Judgment Notwithstanding the Verdict 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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