A motion for directed verdict is a motion by a party asking the trial judge to issue a ruling after determining that there is no legally sufficient evidentiary basis for a reasonable
Rule 50(a) of the Federal Rules of Civil Procedure empowers a judge to determine an issue himself, rather than submitting it to the jury, when the evidence is insufficient for a reasonable jury to conclude to the contrary. When the judge's determination of the particular issue makes it impossible for the losing party to prevail in its overall claim or defense, the judge will enter a "judgment as a matter of law" against the party. Because such a judgment deprives the losing party of its constitutional right to a jury trial, the rules governing the exercise of Rule 50(a) power are very important. This case addresses a significant question about these rules: may a court of appeal review the sufficiency of evidence presented at trial, when a party loses a pre-verdict motion for judgment as a matter of law under Rule 50(a), but then fails to renew the motion under Rule 50(b) after the jury has reached a verdict? The Supreme Court's resolution will greatly impact the speed and quality of review of trial court decisions by courts of appeal, as well as the power these courts possess to overturn improper verdicts.
Whether, and to what extent, a court of appeals may review the sufficiency of evidence supporting a civil verdict where the party requesting review made a motion for judgment as a matter of law under Rule 50(a) of the Federal Rules of Civil Procedure before submitting the case to the jury, but neither renewed that motion under Rule 50(b) after the jury's verdict nor moved for a new trial under Rule 59?
Unitherm Food Systems ("Unitherm"), a manufacturer and supplier of food processing machinery, sued Swift-Eckrich, doing business as ConAgra Refrigerated Foods ("ConAgra"), for defrauding the Patent Office, misrepresenting itself to Unitherm, improperly interfering with Unitherm's prospective business relations, and monopolistic practices in violation of
