Rule 50.Judgment as a matter of law in jury trials; alternative motion for new trial; conditional rulings
Group 6: Trials · Last amended September 1, 2005 · Last verified July 13, 2026
In one sentenceRule 50 lets a Washington superior court enter judgment as a matter of law when no reasonable jury could find for the opposing party, and lets the losing movant renew that request, with an alternative new-trial motion, within ten days after judgment.
(1)Nature and effect of motion. If, during a trial by jury, a party has been fully heard with respect to an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find or have found for that party with respect to that issue, the court may grant a motion for judgment as a matter of law against the party on any claim, counterclaim, cross claim, or third party claim that cannot under the controlling law be maintained without a favorable finding on that issue. Such a motion shall specify the judgment sought and the law and the facts on which the moving party is entitled to the judgment. A motion for judgment as a matter of law which is not granted is not a waiver of trial by jury even though all parties to the action have moved for judgment as a matter of law.
(2)When made. A motion for judgment as a matter of law may be made at any time before submission of the case to the jury.
(b)Renewing motion for judgment after trial; alternative motion for new trial. If, for any reason, the court does not grant a motion for judgment as a matter of law made at the close of all the evidence, the court is considered to have submitted the action to the jury subject to the court’s later deciding the legal questions raised by the motion. The movant may renew its request for judgment as a matter of law by filing a motion no later than 10 days after entry of judgment — and may alternatively request a new trial or join a motion for a new trial under rule 59. In ruling on a renewed motion, the court may:
(1)if a verdict was returned:
(A)allow the judgment to stand,
(B)order a new trial, or
(C)direct entry of judgment as a matter of law; or
(2)if no verdict was returned:
(A)order a new trial, or
(B)direct entry of judgment as a matter of law.
(c)Alternative motions for judgment as a matter of law or for a new trial — Effect of appeal. Whenever a motion for a judgment as a matter of law and, in the alternative, for a new trial shall be filed and submitted in any superior court in any civil cause tried before a jury, and such superior court shall enter an order granting such motion for judgment as a matter of law, such court shall at the same time, in the alternative, pass upon and decide in the same order such motion for a new trial; such ruling upon said motion for a new trial not to become effective unless and until the order granting the motion for judgment as a matter of law shall thereafter be reversed, vacated, or set aside in the manner provided by law. An appeal to the Supreme Court or Court of Appeals from a judgment granted on a motion for judgment as a matter of law shall, of itself, without the necessity of cross appeal, bring up for review the ruling of the trial court on the motion for a new trial; and the appellate court shall, if it reverses the judgment entered as a matter of law, review and determine the validity of the ruling on the motion for a new trial.
(d)Same: denial of motion for judgment as a matter of law. If the motion for judgment as a matter of law is denied, the party who prevailed on that motion may, as appellee, assert grounds entitling the party to a new trial in the event the appellate court concludes that the trial court erred in denying the motion for judgment. 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.
Amendment History
Prior: 50(a), RPPP Rule 50; 50(c) and (d), RPPP Rule 59.08W. Adopted May 5, 1967, amended June 28, 1967, effective July 1, 1967; amended, adopted Aug. 9, 1976, effective Jan. 1, 1977; amended, adopted May 7, 1980, effective July 1, 1980; amended, adopted June 14, 1984, effective Sept. 1, 1984; amended, adopted Sept. 2, 1993, effective Sept. 24, 1993, amended June 2, 2005, effective Sept. 1, 2005.
Plain-English Summary
Rule 50 gives a party a way to short-circuit a jury's decision when the evidence won't support the other side. If a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on it, the court may enter judgment as a matter of law against them on any claim, counterclaim, cross claim, or third party claim that can't stand without a favorable finding on that issue. The motion has to spell out the judgment sought and the law and facts behind it, and losing the motion doesn't waive a party's right to a jury trial, even where both sides moved for judgment as a matter of law. The motion can be made any time before the case goes to the jury.
If the court doesn't grant that motion at the close of all the evidence, the case is treated as submitted to the jury subject to the court later deciding the legal questions the motion raised. The moving party can renew the request after trial by filing a motion no later than ten days after entry of judgment, and can pair it with, or use in its place, a request for a new trial under Rule 59. On a renewed motion, the court's options depend on whether the jury reached a verdict: if it did, the court can let the judgment stand, order a new trial, or direct entry of judgment as a matter of law; if no verdict was returned, the court can order a new trial or direct entry of judgment as a matter of law. This renewed, post-verdict motion is what practitioners in other jurisdictions often still call a motion for judgment notwithstanding the verdict, or JNOV, even though Washington's rule folds it into the same judgment-as-a-matter-of-law framework, sometimes shortened to JMOL.
Rule 50 also manages what happens when a party combines a judgment-as-a-matter-of-law motion with an alternative motion for a new trial. If the trial court grants judgment as a matter of law, it must rule on the alternative new-trial motion in the same order, but that new-trial ruling only takes effect if the judgment as a matter of law is later reversed, vacated, or set aside. An appeal from a judgment entered on such a motion automatically brings up the trial court's ruling on the new-trial motion for review, without any need for a separate cross appeal, and the appellate court must review that new-trial ruling if it reverses the judgment as a matter of law.
The rule closes by protecting the party who successfully fought off a judgment-as-a-matter-of-law motion. If that motion was denied, the prevailing party may, as appellee, argue on appeal that it's entitled to a new trial in case the appellate court decides the trial court should have granted judgment as a matter of law, and the appellate court can either grant that new trial itself or direct the trial court to decide whether one should be granted.
Frequently Asked Questions
Is Washington's Rule 50 the same thing as a JNOV motion?
Washington's rule calls it judgment as a matter of law, but the renewed, post-verdict version under subsection (b) serves the same function traditionally called judgment notwithstanding the verdict, or JNOV, and is often referred to today as JMOL.
When during trial can a party move for judgment as a matter of law?
Any time before the case is submitted to the jury.
How long after judgment does a party have to renew a motion for judgment as a matter of law?
No later than ten days after entry of judgment.
Can a party ask for a new trial and judgment as a matter of law in the same motion?
Yes. The renewed motion can be paired with an alternative request for a new trial, or joined with a motion for new trial under Rule 59.
What happens on appeal if the trial court grants judgment as a matter of law along with an alternative new-trial ruling?
The appeal automatically brings up the new-trial ruling for review without a separate cross appeal, and the appellate court must review that ruling if it reverses the judgment as a matter of law.
Does losing a motion for judgment as a matter of law waive a party's right to a jury trial?
No. A motion that is not granted is not treated as a waiver of trial by jury, even if all parties moved for judgment as a matter of law.
What can the court do on a renewed motion if the jury never reached a verdict?
Order a new trial or direct entry of judgment as a matter of law.
Can the party who defeated a judgment-as-a-matter-of-law motion still get a new trial?
Yes. If the appellate court concludes the trial court erred in denying that motion, the prevailing party may, as appellee, assert grounds for a new trial, and the appellate court may grant one or send the question back to the trial court.
Source & verification. Rule text and amendment history are
reproduced verbatim from the Washington Superior Court Civil Rules, adopted by the
Supreme Court of Washington. Last verified July 13, 2026. ·
Official source
Also known as:JNOV washingtonJMOL washington civil procedurejudgment notwithstanding the verdict washingtonmotion for judgment as a matter of law CR 50renewed motion for judgment after trial washingtonCR 50 washington