Ward and Smith appellate attorney Chris Edwards is featured in the Appellate Thinking section of the North Carolina Advocates for Justice’s Trial Briefs (Fall 2025 issue).
His article, “Making JNOV Stick: Lessons from the Vanguard Decision,” draws on his extensive appellate experience to guide attorneys through post-verdict practice, specifically focusing on the strategic crafting of motions for judgment notwithstanding the verdict following challenging appellate outcomes.
In the article, Chris examines the Vanguard decision and walks readers through the standards for preserving issues, framing arguments, and leveraging precedent to strengthen the likelihood of success on appeal. His analysis provides both a practical roadmap and an informed perspective rooted in his board-certified appellate practice.
From the article:
Vanguard reinforces the critical role of detailed, strategic motion practice at trial. Whether you're opposing a JNOV, defending your plaintiff's verdict on appeal, or making your own JNOV motion, these tips will help you make the most of the stringent specificity requirement.
First, be specific, even if it feels redundant. Directed verdict and JNOV motions should be directed to specific claims, elements, or evidentiary deficiencies. If you're defending against such a motion, monitor to see if your opponent over generalizes.
Read the full article in Trial Briefs to explore Chris's complete analysis.
