A plaintiff sued a defendant for patent infringement in federal court. After the plaintiff presented all evidence, the defendant moved for judgment as a matter of law (JMOL), arguing that no reasonable jury could find for the plaintiff. The court denied the motion. The jury subsequently returned a verdict for the plaintiff. Within the permissible timeframe, the defendant filed a *renewed* motion for judgment as a matter of law (RJML), again arguing insufficient evidence. The court granted the RJML, overturning the jury's verdict. The plaintiff appeals this decision. What standard of review will the appellate court apply to the district court's decision to grant the RJML?
- AClearly erroneous.
- BSubstantial evidence.
- CAbuse of discretion.
- DDe novo.
Show answer & explanationAnswer & explanation
Correct answer: D. De novo.
An appellate court reviews a district court's decision to grant or deny a renewed motion for judgment as a matter of law (RJML) de novo. This means the appellate court applies the same standard as the district court: whether a reasonable jury would have a legally sufficient evidentiary basis to find for the party on that issue. The appellate court does not defer to the district court's judgment on the sufficiency of the evidence.
Why the other options are wrong
- A. Clearly erroneous is the standard for reviewing a district court's findings of fact in a bench trial, not for reviewing a JMOL/RJML decision in a jury trial.
- B. Substantial evidence is a standard used in administrative law review or sometimes for reviewing jury verdicts in specific contexts, but 'de novo' is the specific and most accurate standard for RJML.
- C. Abuse of discretion is typically used for discretionary rulings, like discovery orders or evidentiary admissions, not for questions of law or sufficiency of evidence.
Appellate Review of RJML
An appellate court reviews a district court's decision on a renewed motion for judgment as a matter of law (RJML) de novo. This means the appellate court independently assesses whether the evidence, viewed in the light most favorable to the non-moving party, is legally sufficient to support the jury's verdict.
- Applies the same standard as the district court.
- Looks for a 'legally sufficient evidentiary basis' for the jury's verdict.
- Does not defer to the district court's assessment of the evidence.
Memory trick: Appeals: Law is De Novo, Facts are Clearly Wrong, Discretion is Abused.