50.01 When Made -- Effect. A motion for a directed verdict may be made at the close of the evidence offered by an opposing party or at the close of the case. The court shall reserve ruling until all parties alleging fault against any other party have presented their respective proof-in-chief. A party who moves for a directed verdict at the close of the evidence offered by an opponent may offer evidence in the event that the motion is not granted, without having reserved the right so to do and to the same extent as if the motion had not been made. A motion for a directed verdict which is not granted is not a waiver of trial by jury even though all parties to the action have moved for directed verdicts. The order of the court granting a motion for a directed verdict is effective without any assent of the jury.
Rule 50.Motion for a Directed Verdict
Last verified July 2, 2026
In one sentenceRule 50 lets a party move for a directed verdict at the close of an opponent’s proof or at the close of all the evidence, lets the court reserve ruling on a motion made at the close of all evidence and decide it after the verdict instead, and no longer requires a motion for new trial to appeal a directed verdict the court did grant.
Full Text of Rule 50
50.02 Reservation of Decision on Motion. Whenever a motion for a directed verdict made at the close of all the evidence is denied or for any reason is not granted, the court is deemed to have submitted the action to the jury subject to a later determination of the legal questions raised by the motion. Within thirty (30) days after the entry of judgment a party who has moved for a directed verdict may move to have the verdict and any judgment entered thereon set aside and to have judgment entered in accordance with the party's motion for a directed verdict; or if a verdict was not returned, such party, within thirty (30) days after the jury has been discharged, may move for a judgment in accordance with such party's motion for a directed verdict. A motion for a new trial may be joined with this motion, or a new trial may be prayed for in the alternative. If a verdict was returned, the court may allow the judgment to stand or may reopen the judgment and either order a new trial or direct the entry of judgment as if the requested verdict had been directed. If no verdict was returned the court may direct the entry of judgment as if the requested verdict had been directed or may order a new trial.
50.03 Conditional Rulings on Grant of Motion. If the motion for judgment entered in accordance with a motion for a directed verdict, provided for in 50.02, is granted, the court shall also rule on the motion for a new trial, if any, by determining whether it should be granted if the judgment is thereafter vacated or reversed, and shall specify the grounds for granting or denying the motion for a new trial. If the motion for a new trial is thus conditionally granted, the order thereon does not affect the finality of the judgment. If the motion for a new trial is thus conditionally granted and the judgment is reversed on appeal, the new trial shall proceed unless the appellate court has otherwise ordered. In case the motion for a new trial has been conditionally denied, the appellee on appeal may assert error in that denial; and if the judgment is reversed on appeal, subsequent proceedings shall be in accordance with the order of the appellate court. The party whose verdict has been set aside on motion to have judgment entered in accordance with a motion for a directed verdict, as provided for in 50.02, may serve a motion for a new trial not later than thirty (30) days after entry of the judgment granting the motion.
50.04 Denial of Motion. If the motion for judgment entered in accordance with a motion for a directed verdict, as provided for in 50.02, is denied, the party who prevailed on that motion may, as appellee, by assignments of error assert grounds entitling him to a new trial. 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 shall be granted.
50.05 Motion for New Trial Not Necessary after Directed Verdict. Whenever a court shall have granted a directed verdict, it shall not be necessary for the party against whom the verdict was directed to file a motion for a new trial in order to obtain appellate review of such action of the court.
Advisory Commission Comments
Advisory Commission Comments.
[1998]. Adding the sentence in Rule 50.01 concerning reservation of a ruling was thought necessary in light of Tennessee's adoption of comparative fault.
Plain-English Summary
Rule 50.01 lets a party move for a directed verdict either at the close of the evidence an opposing party has offered or at the close of the whole case, though the court has to hold off ruling until every party alleging fault against another has finished presenting its own proof — a sequencing rule tied to Tennessee’s comparative-fault system, where a defendant’s own share of fault can depend on evidence another party hasn’t yet put on. Moving for a directed verdict at the close of an opponent’s evidence does not force a party to rest; it can still put on its own proof if the motion is denied, exactly as if it had never moved at all. Losing a directed-verdict motion is not treated as giving up the right to a jury trial, even if every party in the case has made the same kind of motion, and a court’s order granting a directed verdict takes effect without needing the jury’s own assent.
Rule 50.02 covers what happens when a motion made at the close of all the evidence is denied, or the court declines to rule on it: the case still goes to the jury, but the legal questions the motion raised stay open for the court to resolve later. Within 30 days after judgment is entered — or, if the jury never returned a verdict, within 30 days after it was discharged — the moving party can ask the court to set aside the verdict, if there was one, and enter judgment consistent with the earlier directed-verdict motion. A motion for a new trial can be joined with this request, or requested as a fallback. If a verdict was returned, the court can let the judgment on it stand, or reopen the case and either order a new trial or enter judgment as though it had directed the verdict at trial. If no verdict was returned at all, the court has the same two options — enter judgment as though the verdict had been directed, or order a new trial.
Rule 50.03 requires a court that grants this kind of post-trial judgment to also rule, at the same time, on any accompanying motion for a new trial — deciding conditionally whether a new trial should happen if the judgment is later vacated or reversed on appeal, and stating its grounds either way. That conditional ruling does not affect the finality of the judgment being appealed. Rule 50.04 covers the reverse situation: if the court denies the post-trial motion, the party who won that motion can still argue on appeal that it deserves a new trial, and an appellate court that reverses the judgment is free to address that new-trial argument or send it back to the trial court to decide.
Rule 50.05 removes an old formality: a party against whom the court directed a verdict does not have to file a separate motion for a new trial just to get appellate review of that ruling — the fact that the trial court’s own action, not the jury’s, produced the verdict is enough to preserve the issue for appeal.
Frequently Asked Questions
When can a party move for a directed verdict?
Rule 50.01 allows the motion at the close of the evidence offered by an opposing party, or at the close of the whole case, though the court must wait to rule until every party alleging fault against another has finished presenting its own proof.
What happens if a directed-verdict motion made at the close of all evidence isn’t ruled on before the case goes to the jury?
Rule 50.02 treats the case as submitted to the jury subject to a later ruling. Within 30 days after judgment — or after the jury is discharged if no verdict was returned — the moving party can ask the court to enter judgment consistent with the earlier motion.
Do I need to file a motion for a new trial after the court directs a verdict against me?
No. Rule 50.05 removes that requirement — a party against whom a verdict was directed can seek appellate review of that ruling without first filing a motion for a new trial.
Source & verification. The rule text and Advisory Commission Comments are reproduced verbatim from the
official Tennessee Rules of Civil Procedure (Tenn. R. Civ. P. 50). Prescribed by the Supreme Court of Tennessee (Tenn. Code Ann. §§ 16-3-402 to 16-3-407, 16-3-601). The plain-English summary is original and written by us. Last verified July 2, 2026. ·
Official source
Also known as: directed verdictmotion for directed verdictjudgment notwithstanding the verdict
Advisory Commission Comments.
50.01: It is not the intention of these Rules to affect constitutional powers or jurisdictional rules. This Rule therefore does not enlarge or restrict a chancery court's authority to withdraw issues from the jury. It simply describes the procedure to be followed in directing verdicts in chancery cases as well as in circuit cases, subject always to any constitutional or jurisdictional limitations.
50.02: This Rule permits a trial judge to take under advisement a motion for directed verdict without actually granting or denying it at the trial. The power of the court to grant a directed verdict on post-trial motion, either following a verdict or in event of a mistrial because of disagreement of the jury, has long been recognized in Tennessee. This Rule, however, does permit the filing of a post trial motion for directed verdict without its being incorporated into a motion for a new trial although the latter is still permitted.
50.05: This Rule eliminates the previous requirement that a party against whom a verdict has been directed must file a motion for a new trial in order to obtain appellate review of the action of the court in directing the verdict. The former rule was technical in the extreme, especially when the directed verdict came on post-trial motion of the defendant; in such cases, if the plaintiff failed to make a subsequent motion for new trial, he or she could not obtain review of the action of the trial court. SeeHowell v. Wallace E. Johnson, Inc., 42 Tenn. App. 15, 298 S.W.2d 753 (1956). The action of a trial court in directing a verdict, of course, is not the action of the jury. Previous procedure has not required a motion for a new trial in nonjury proceedings. Tenn. Code Ann. § 27-303 et seq. [repealed]. This Rule seems to the Committee therefore to be consistent with the previous rules in nonjury proceedings.