Dupree v. Younger

Kevin Younger, a former Maryland prisoner, sued correctional officer Neil Dupree for using excessive force. At trial, Dupree moved for judgment as a matter of law under Rule 50(a) after Younger’s case, which was denied. After the jury found for Younger, Dupree renewed the motion under Rule 50(b) on a purely legal issue. The district court granted the motion. The Fourth Circuit held that Dupree had not preserved the precise legal argument in his pre-verdict motion, thus waiving appeal. The Supreme Court reversed, holding that when a district court grants a renewed Rule 50(b) motion on a purely legal question, appellate courts must review that legal ruling de novo, regardless of whether the issue was specifically raised in the Rule 50(a) motion.

The U.S. Supreme Court unanimously reversed and remanded, holding that the purely legal basis for a granted Rule 50(b) motion is reviewable de novo on appeal, even if not previously stated in the Rule 50(a) motion.

Whether a party must reassert a purely legal argument in a pre-verdict Rule 50(a) motion to preserve it for appellate review when the district court later grants a post-verdict Rule 50(b) motion on that same legal ground.

The decision resolved a deep circuit split and removed a procedural trap that had caused many litigants to forfeit meritorious legal arguments. By confirming that issue preservation requirements do not apply to purely legal questions actually decided by the district court, it promotes fairness, simplifies civil appeals, and ensures cases are resolved on their substantive legal merits.