A directed verdict is a ruling by a trial judge that concludes a case after determining the evidence presented is legally insufficient for a reasonable jury to reach a decision. This article explains the directed verdict process as it functions within Georgia’s state courts, governed by specific statutes and legal precedents.
Understanding a Directed Verdict in Georgia Courts
A directed verdict serves the purpose of resolving a case, or certain issues within it, when one party’s evidence is so weak that it cannot legally support a verdict in their favor. It is a judgment made by the judge “as a matter of law,” which means the judge has concluded there is no legitimate factual dispute for a jury to resolve. This promotes judicial efficiency by preventing cases from being decided by a jury when the outcome is already legally certain.
This judicial tool is distinct from a summary judgment motion, which is decided before a trial begins based on affidavits and discovery documents. A directed verdict, in contrast, occurs during the trial itself, after one or both parties have had the opportunity to present their evidence. The judge’s ruling is based solely on the testimony and exhibits admitted during the trial proceedings.
Timing for a Directed Verdict Motion in Georgia Trials
The timing for making a directed verdict motion is explicitly defined in Georgia law. In civil proceedings, a defendant can move for a directed verdict at the conclusion of the evidence presented by the plaintiff. This allows the defendant to challenge the adequacy of the plaintiff’s case before having to present their own evidence.
Both parties in a civil case have the opportunity to move for a directed verdict at the close of all evidence, after the defense has presented its case and any rebuttal evidence has been offered. The motion must be made before the case is submitted to the jury for deliberation.
In criminal trials, the procedure is similar. The defendant may make a motion for a directed verdict at the close of the state’s evidence, arguing that the prosecution has failed to prove guilt beyond a reasonable doubt.1FindLaw. Georgia Code Title 17. Criminal Procedure § 17-9-1 This motion can also be made at the close of all evidence in the case.
Legal Standards for Granting a Directed Verdict in Georgia
The legal standard for granting a directed verdict in Georgia is demanding. The controlling statute, O.C.G.A. § 9-11-50, states that a verdict shall be directed “If there is no conflict in the evidence as to any material issue and the evidence introduced, with all reasonable deductions therefrom, shall demand a particular verdict.”2Justia. Georgia Code § 9-11-50 (2024) – Motions for Directed Verdict and for Judgment Notwithstanding the Verdict This language sets a high bar for the moving party.
To meet this standard, the evidence must be so one-sided that there is no room for a reasonable difference of opinion. If even a slight doubt or a question of fact exists on a material point, the motion must be denied, and the issue must be sent to the jury.
When evaluating the motion, the judge is required to view all evidence in the light most favorable to the party opposing the motion. This means the judge must assume that the non-moving party’s evidence is true and give them the benefit of all reasonable inferences that can be drawn from it. The court cannot weigh the credibility of witnesses or compare the strength of competing evidence; its sole function is to determine if the non-moving party has presented any evidence to support their claim.
The Motion and Judicial Review Process for a Directed Verdict
A party initiates the process by making a formal motion for a directed verdict to the court. This can be done orally in open court, which is common during a trial, or it can be submitted in writing. The motion must state the specific grounds for why the directed verdict should be granted, clearly identifying the deficiencies in the opposing party’s evidence.
The judge’s review is strictly limited to the evidence that has been formally presented in the trial up to that point. The court does not consider potential evidence or resolve conflicts in testimony, as its role is not to assess the believability of witnesses.
The judge will hear legal arguments from the attorneys for both sides. The moving party’s lawyer will highlight the lack of evidence on an element of the case, while the opposing counsel will point to the specific testimony or exhibits that they believe create a question of fact for the jury.
Outcomes Following a Judge’s Ruling on a Directed Verdict
If the motion is granted, the judge will issue an order for a directed verdict, and a final judgment is entered in favor of the moving party on the specific claims addressed. This action effectively terminates that portion of the case, or sometimes the entire lawsuit, without any deliberation by the jury.
Conversely, if the motion is denied, the trial simply continues from where it left off. The case, or the specific claims at issue, will then proceed to the next phase, which is the submission of the case to the jury for a verdict.
In civil cases, a party whose motion was denied still has recourse if the jury returns an unfavorable verdict. The party can file a motion for judgment notwithstanding the verdict (JNOV), which asks the judge to set aside the jury’s verdict and enter judgment in their favor. This post-verdict motion is not available in criminal proceedings. In either type of case, a judge’s ruling on a directed verdict motion can serve as a basis for an appeal after the trial has concluded.