JNOV

A "JNOV" is a "judgment notwithstanding verdict," which means a judge's decision to overrule the verdict by rendered by a jury in a lawsuit.

In New York state court, a litigant must bring a motion for JNOV within 15 days of the entering of the verdict. Specifically, NY CLS CPLR R 4405 (Time and judge before whom post-trial motion made) requires that:

A motion under this article shall be made before the judge who presided at the trial within fifteen days after decision, verdict or discharge of the jury. The court shall have no power to grant relief after argument or submission of an appeal from the final judgment.

The timing of this deadline has been an issue of some dispute, but all reported decisions have held that the time begins when the decision is filed:

Bernstein v Swidunovich (1964) 44 Misc 2d 728, 254 NYS2d 863 (15 days begins running from the date the decision is filed)

Arlen of Nanuet, Inc. v State (1967) 52 Misc 2d 1009, 277 NYS2d 560 (the date for starting the 15-day period is when the decision is filed)

Wierzbieniec v Przewlocki (1967) 54 Misc 2d 83, 281 NYS2d 447 (one month afterwards is too late;the filing of a written decision begins the 15-day period)

Hamel v Hamel (1982, Fam Ct) 117 Misc 2d 118, 457 NYS2d 729 (15-day period begins when the order is signed, not when a written decision is rendered)