Question

A mayor sued a blogger for defamation in federal district court under diversity jurisdiction. The mayor alleged in her complaint that the blogger had published defamatory statements about her that suggested she was having an adulterous relationship. The mayor's entire case rested on her own testimony establishing the prima facie elements of her claim and a properly authenticated and admitted copy of the allegedly defamatory publication. At the end of the mayor's presentation of evidence to the jury, the blogger filed a motion for judgment as a matter of law. Finding that the mayor's meager evidence was insufficient for a jury reasonably to find that the publication was false, as was required by state law, the judge granted the blogger's motion and directed a judgment in favor of the blogger. The mayor immediately appealed the judgment, contending that the trial judge applied the wrong legal standard in granting the motion.

On these facts, should the judgment be set aside on appeal?
A. No, because the district court's ruling was not clearly erroneous.
B. No, because the mayor failed to meet her burden of establishing a prima facie case as a matter of law.
C. Yes, because a motion for judgment as a matter of law cannot be granted until both parties have presented their cases.
D. Yes, because the district court improperly evaluated the weight of the evidence.

Answer 1

Answer:Answer choice D is correct. When ruling on a Rule 50 motion for judgment as a matter of law, the court must view the evidence in the light most favorable to the opposing party and draw all reasonable inferences from the evidence in favor of the opposing party. It may not consider the credibility of witnesses or evaluate the weight of the evidence, and it must disregard all evidence favorable to the moving party that the jury is not required to believe. Therefore, on these facts, the district court improperly granted the blogger's motion, and the ruling should be set aside.

Step-by-step explanation:

Answer choice A is incorrect because it states the incorrect standard to be applied when reviewing a judgment as a matter of law. Appellate review of legal rulings is de novo. The appeals court will use the trial court's record, but it reviews the evidence and law without deference to the trial court's rulings.

Answer choice B is incorrect because the mayor met this burden by testifying that the publication was false. The credibility of this testimony must be assessed by the jury.

Answer choice C is incorrect because a motion for judgment as a matter of law may be made at any time before the case is submitted to the jury.