American National Fire Insurance Co. v. Hughes – Case Brief Summary (Alabama)

In American National Fire Insurance Co. v. Hughes, 624 So. 2d 1362 (Ala. 1993), the Court stated the standard that applies to appellate review of a trial court's ruling on a motion for a judgment as a matter of law:

"The standard of review applicable to a ruling on a motion for JNOV is identical to the standard used by the trial court in granting or denying a motion for directed verdict. Thus, in reviewing the trial court's ruling on the motion, we review the evidence in a light most favorable to the nonmovant, and we determine whether the party with the burden of proof has produced sufficient evidence to require a jury determination.


"... In ruling on a motion for a JNOV, the trial court is called upon to determine whether the evidence was sufficient to submit a question of fact to the jury; for the court to determine that it was, there must have been 'substantial evidence' before the jury to create a question of fact. 'Substantial evidence is evidence of such weight and quality that fair-minded persons in the exercise of impartial judgment can reasonably infer the existence of the fact sought to be proved.'" 624 So. 2d at 1366-67 .