2-1202.Reserved ruling on motion for directed verdict - Post-trial motions in jury cases.
Article II. Civil Practice · Part 12. Post-Trial · Not amended since adoption on record · Last verified July 20, 2026
In one sentenceSection 2-1202 governs post-trial motions after an Illinois jury trial -- including judgment notwithstanding the verdict -- and requires every request for post-trial relief to go into one motion filed within 30 days.
(a)If at the close of the evidence, and before the case is submitted to the jury, any party moves for a directed verdict the court may (1) grant the motion or (2) deny the motion or reserve its ruling thereon and submit the case to the jury. If the court denies the motion or reserves its ruling thereon, the motion is waived unless the request is renewed in the post-trial motion.
(b)Relief desired after trial in jury cases, heretofore sought by reserved motions for directed verdict or motions for judgment notwithstanding the verdict, in arrest of judgment or for new trial, must be sought in a single post-trial motion. Relief after trial may include the entry of judgment if under the evidence in the case it would have been the duty of the court to direct a verdict without submitting the case to the jury, even though no motion for directed verdict was made or if made was denied or ruling thereon reserved. The post-trial motion must contain the points relied upon, particularly specifying the grounds in support thereof, and must state the relief desired, as for example, the entry of a judgment, the granting of a new trial or other appropriate relief. Relief sought in post-trial motions may be in the alternative or may be conditioned upon the denial of other relief asked in preference thereto, as for example, a new trial may be requested in the event a request for judgment is denied.
(c)Post-trial motions must be filed within 30 days after the entry of judgment or the discharge of the jury, if no verdict is reached, or within any further time the court may allow within the 30 days or any extensions thereof. A party against whom judgment is entered pursuant to post-trial motion shall have like time after the entry of the judgment within which to file a post-trial motion.
(d)A post-trial motion filed in apt time stays enforcement of the judgment.
(e)Any party who fails to seek a new trial in his or her post-trial motion, either conditionally or unconditionally, as herein provided, waives the right to apply for a new trial, except in cases in which the jury has failed to reach a verdict.
(f)The court must rule upon all relief sought in all post- trial motions. Although the ruling on a portion of the relief sought renders unnecessary a ruling on other relief sought for purposes of further proceedings in the trial court, the court must nevertheless rule conditionally on the other relief sought by determining whether it should be granted if the unconditional rulings are thereafter reversed, set aside or vacated. The conditional rulings become effective in the event the unconditional rulings are reversed, set aside or vacated.
Plain-English Summary
Before a case reaches the jury, a party can move for a directed verdict at the close of the evidence. The court can grant it, deny it, or reserve its ruling and send the case to the jury anyway. Denying or reserving the motion doesn't kill it forever, but it does waive it unless the party renews the request in a post-trial motion.
After trial, everything a party might have once sought through separate motions -- judgment notwithstanding the verdict, arrest of judgment, or a new trial -- now has to go into a single post-trial motion. That motion must spell out every ground with particularity and state exactly what relief it wants. Relief can include entry of judgment outright, even without an earlier directed-verdict motion, if the evidence would have required the court to direct a verdict. A party can also ask for relief in the alternative, such as a new trial if the request for judgment is denied.
The motion is due within 30 days of the judgment or the jury's discharge (if it never reached a verdict), or within any extension the court allows inside that window. A party who ends up with judgment entered against them because of someone else's post-trial motion gets that same 30 days to file their own. A timely motion automatically stays enforcement of the judgment, and skipping a request for a new trial in the motion waives that right later, unless the jury failed to reach a verdict at all.
Finally, the trial court has to rule on every form of relief the motion seeks. Even where one ruling makes other requested relief unnecessary for now, the court still has to rule on it conditionally, so that ruling springs to life automatically if an appeals court reverses or vacates the main ruling.
Frequently Asked Questions
What is the Illinois equivalent of a motion for judgment notwithstanding the verdict?
Illinois folds that request into the single post-trial motion required by subsection (b), which can seek judgment, a new trial, or other relief, including in the alternative.
Do I have to move for a directed verdict during trial before I can seek judgment after the verdict?
Not always. The text allows entry of judgment after trial if the evidence would have required a directed verdict, even where no directed-verdict motion was made, denied, or left unresolved.
How long do I have to file a post-trial motion after an Illinois jury trial?
30 days after judgment is entered or the jury is discharged without a verdict, or any further time the court allows within that 30-day period or its extensions.
Does filing a post-trial motion stop the winning party from collecting on the judgment?
Yes. A post-trial motion filed in apt time stays enforcement of the judgment while it's pending.
Can I ask for a new trial and judgment notwithstanding the verdict in the same motion?
Yes. The statute allows relief in the alternative, or conditioned on the denial of a preferred remedy -- for example, a new trial only if the request for judgment fails.
Amendment History
(Source: P.A. 82-280.)
Source & verification. Section text and amendment history are
reproduced verbatim from the Illinois Compiled Statutes, published by the
Illinois Compiled Statutes, Illinois General Assembly / Legislative Reference Bureau. Last verified July 20, 2026.
· Official source
Also known as:JNOV illinoisjudgment notwithstanding the verdict illinoisJMOL equivalent illinoispost-trial motion illinois jury trialdirected verdict illinoismotion for new trial illinois