Chris Brown, owner of Tattooed Millionaire Entertainment production company and the House of Blues, along with studio lessees John Falls and Daniel Mott, filed an approximate $10.5 million claim with Hanover Insurance for property damage and theft extending from a Novembreak-in at the studio. Tattooed Millionaire arises from insurance fraud for ostensible arson, burglary, and vandalism of the historic House of Blues music studio in Memphis, Tennessee. Tattooed Millionaire Entertainment, the Sixth Circuit linked arms with its sister circuits and held, unequivocally (and to the great relief of bar review courses everywhere), “no.” I was therefore surprised to learn that the Sixth Circuit had never expressly decided the question- i.e., whether a party can make a renewed motion for JMOL under FRCP 50(b) if it has not made a pre-verdict JMOL motion under FRCP 50(a). ![]() ![]() Lest I be tempted to believe I latched onto this rule because I’m a litigator, the reality is I remember the rule because it’s so simple: if you fail to move for JMOL before the case is submitted to the jury, you can’t make a renewed JMOL motion after a verdict has been rendered. For me, that line of questioning is civil procedure, and more specifically, judgment as a matter of law (“JMOL”). Most readers, I assume, will have had at least one experience preparing for and taking the bar exam, and most, I further assume, will have at least one line of questioning forever burned into their brains, regardless of utility to later practice. Cliché though it may be, the analogy serves as a useful reminder that the exam tests candidates largely on settled, black-letter law rather than novel questions typical of law school exams. ![]() The bar exam, so the saying goes, is like fording a river that is a mile wide but only an inch deep. By Squire Patton Boggs on OctoPosted in Recent Cases
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