(a) When permitted. — In a jury trial, a party may move for judgment notwithstanding the verdict only if that party made a motion for judgment at the close of all the evidence and only on the grounds advanced in support of the earlier motion.
Rule 2-532.Motion for judgment notwithstanding the verdict
Circuit Court · Last amended July 1, 2023 · Last verified July 13, 2026
In one sentenceLets a party who already moved for judgment at the close of all the evidence ask the court to set aside an adverse jury verdict, on a strict ten-day filing deadline.
Full Text of Rule 2-532
(b) Time for filing. — The motion shall be filed within ten days after entry of judgment on the verdict or, if no verdict is returned, within ten days after the discharge of the jury. If the court reserves ruling on a motion for judgment made at the close of all the evidence, that motion becomes a motion for judgment notwithstanding the verdict if the verdict is against the moving party or if no verdict is returned. A motion for judgment notwithstanding the verdict filed after the announcement or signing by the trial court of a judgment or the return of a verdict but before entry of the judgment on the docket shall be treated as filed on the same day as, but after, the entry on the docket.
(c) Joinder with motion for new trial. — A motion for judgment notwithstanding the verdict may be joined with a motion for a new trial.
(d) Effect of failure to make motion. — Failure to move for a judgment notwithstanding the verdict under this Rule does not affect a party’s right upon appeal to assign as error the denial of that party’s motion for judgment.
(e) Disposition. — If a verdict has been returned, the court may deny the motion, or it may grant the motion, set aside any judgment entered on the verdict, and direct the entry of a new judgment. If a verdict has not been returned, the court may grant the motion and direct the entry of judgment or order a new trial. If a party’s motion for judgment notwithstanding the verdict is granted, the court at the same time shall decide whether to grant that party’s motion for new trial, if any, should the judgment thereafter be reversed on appeal.
(f) Effect of reversal on appeal. —
(1) When Judgment Notwithstanding the Verdict Granted. — If a motion for judgment notwithstanding the verdict is granted and the appellate court reverses, it may (A) enter judgment on the original verdict, (B) remand the case for a new trial in accordance with a conditional order of the trial court, or (C) itself order a new trial. If the trial court has conditionally denied a motion for new trial, the appellee may assert error in that denial and, if the judgment notwithstanding the verdict is reversed, subsequent proceedings shall be in accordance with the order of the appellate court.
(2) When Judgment Notwithstanding the Verdict Denied. — If a motion for judgment notwithstanding the verdict has been denied and the appellate court reverses, it may (A) enter judgment as if the motion had been granted or (B) itself order a new trial. If the motion for judgment notwithstanding the verdict has been denied, the prevailing party may, as appellee, assert grounds entitling that party to a new trial in the event the appellate court concludes that the trial court erred in denying the motion. If the appellate court reverses the judgment, nothing in this Rule precludes it from determining that the appellee is entitled to a new trial or from directing the trial court to determine whether a new trial should be granted.
Amendment History
Amended Oct. 31, 2002, effective Jan. 1, 2003; Nov. 12, 2003, effective Jan. 1, 2004; May 8, 2007, effective July 1, 2007; April 21, 2023, effective July 1, 2023.
Committee Note & Source
Cross references. See Rule 8-205 requiring notice to the Clerk of the Appellate Court of information not disclosed in a Civil Appeal Information Report regarding the filing of a motion under this Rule, or its withdrawal or disposition.
Plain-English Summary
A motion for judgment notwithstanding the verdict — commonly shortened to JNOV — is only available to a party who moved for judgment at the close of all the evidence, and only on the grounds raised in that earlier motion. It has to be filed within ten days after judgment is entered on the verdict, or, if the jury never returned a verdict, within ten days after the jury is discharged. If the trial court reserved ruling on the earlier motion for judgment, that motion automatically becomes a motion for judgment notwithstanding the verdict once the verdict comes back against the moving party, or once it's clear no verdict will be returned. A JNOV motion filed after the court announces or signs judgment, or after the verdict is returned, but before the judgment hits the docket, gets treated as filed the same day as — but after — the docket entry.
A party can join a JNOV motion with a motion for new trial. Failing to file a JNOV motion doesn't cost a party the right to challenge, on appeal, the denial of the original motion for judgment. On disposition, if a verdict came back, the court can deny the motion or grant it, set aside the judgment on the verdict, and direct a new judgment; if no verdict came back, the court can grant the motion and direct entry of judgment, or order a new trial instead. Whenever a court grants a JNOV motion, it must also decide, at the same time, whether it would grant that party's motion for a new trial if the judgment is later reversed on appeal.
Reversal on appeal triggers its own set of options. If the JNOV was granted and the appellate court reverses, that court can enter judgment on the original verdict, remand for a new trial consistent with a conditional order from the trial court, or order a new trial itself; the appellee can raise error in a conditional denial of a new-trial motion. If the JNOV was denied and the appellate court reverses, it can enter judgment as though the motion had been granted, or order a new trial; the party that prevailed below may, as appellee, argue it's entitled to a new trial if the appellate court finds the denial was error.
Frequently Asked Questions
What is a JNOV in Maryland?
A motion for judgment notwithstanding the verdict — JNOV — asks the trial court to set aside a jury verdict. It's only available to a party who already moved for judgment at the close of all the evidence, and only on the grounds raised in that earlier motion.
How long do I have to file a motion for judgment notwithstanding the verdict?
Ten days after judgment is entered on the verdict, or, if no verdict was returned, ten days after the jury is discharged.
Can I combine a JNOV motion with a motion for new trial?
Yes. Rule 2-532(c) allows a party to join the two motions.
What if I never moved for judgment at the close of all the evidence?
Then a JNOV motion isn't available to you. But failing to file one doesn't affect your right on appeal to challenge the denial of your original motion for judgment.
What happens if the trial court reserved its ruling on the original motion for judgment?
That reserved motion automatically converts into a motion for judgment notwithstanding the verdict if the verdict goes against the moving party, or if no verdict is returned at all.
What can an appellate court do if it reverses a granted or denied JNOV?
If the JNOV was granted and reversed, the appellate court can enter judgment on the original verdict, remand for a new trial, or order one itself. If the JNOV was denied and reversed, it can enter judgment as if the motion had been granted or order a new trial.
Source & verification. Rule text, Committee Note, Source note, and
amendment history are reproduced verbatim from the Maryland Rules, adopted by the
Supreme Court of Maryland. Last verified July 13, 2026. ·
Official source
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