Illinois Compiled Statutes
735 ILCS 5/2-1202 (2026)
Reserved ruling on motion for directed verdict - Post-trial motions in jury cases
✓ current as of May 2026
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(735 ILCS 5/2-1202)
(from Ch. 110, par. 2-1202)
Sec. 2-1202.
Reserved ruling on motion for directed verdict - Post-trial
motions in jury cases.
(a) If at the close of the evidence, and before the case is
submitted to the jury, any party moves for a directed verdict the court
may (1) grant the motion or (2) deny the motion or reserve its ruling
thereon and submit the case to the jury. If the court denies the motion
or reserves its ruling thereon, the motion is waived unless the request
is renewed in the post-trial motion.
(b) Relief desired after trial in jury cases, heretofore sought by
reserved motions for directed verdict or motions
for judgment notwithstanding the verdict, in arrest
of judgment or for new trial, must be sought in a single post-trial
motion. Relief after trial may include the entry of judgment if under
the evidence in the case it would have been the duty of the court to
direct a verdict without submitting the case to the jury, even though no
motion for directed verdict was made or if made was denied or ruling
thereon reserved. The post-trial motion must contain the points relied
upon, particularly specifying the grounds in support thereof, and must
state the relief desired, as for example, the entry of a judgment, the
granting of a new trial or other appropriate relief. Relief sought in
post-trial motions may be in the alternative or may be conditioned upon
the denial of other relief asked in preference thereto, as for example,
a new trial may be requested in the event a request for judgment is
denied.
(c) Post-trial motions must be filed within 30 days after the entry
of judgment or the discharge of the jury, if no verdict is reached, or
within any further time the court may allow within the 30 days or any
extensions thereof. A party against whom judgment is entered pursuant to
post-trial motion shall have like time after the entry of the judgment
within which to file a post-trial motion.
(d) A post-trial motion filed in apt time stays enforcement of the
judgment.
(e) Any party who fails to seek a new trial in his or her post-trial
motion, either conditionally or unconditionally, as herein provided,
waives the right to apply for a new trial, except in cases in which the
jury has failed to reach a verdict.
(f) The court must rule upon all relief sought in all post-trial
motions. Although the ruling on a portion of the relief sought renders
unnecessary a ruling on other relief sought for purposes of further
proceedings in the trial court, the court must nevertheless rule
conditionally on the other relief sought by determining whether it
should be granted if the unconditional rulings are thereafter reversed,
set aside or vacated. The conditional rulings become effective in the
event the unconditional rulings are reversed, set aside or vacated.
(Source: P.A. 82-280.)
Notes of Decisions
Cited in 124
cases (31 in the last 5 years), 1994–2026 · leading case: Jacobs v. Yellow Cab Affiliation, Inc., 2017 IL App (1st) 151107 (Ill. App. Ct. 2017).
Jacobs v. Yellow Cab Affiliation, Inc., 2017 IL App (1st) 151107 (Ill. App. Ct. 2017). “Subsequently, pursuant to the rules governing appeals, “A party may not urge as error on review of the ruling on the party’s post-trial motion any point, ground, or relief not specified in the motion.” Ill. S. Ct. R.”
Crim v. Dietrich, 2020 IL 124318 (Ill. 2020). “735 ILCS 5/2-1202 (West 2016). 1 Therefore, according to defendant, the circuit court was barred from relitigating the jury’s verdict.”
Garcia v. Seneca Nursing Home, 2011 IL App (1st) 103085 (Ill. App. Ct. 2011). “¶ 19 Posttrial motions in jury cases are governed by section 2-1202 of the Code of Civil Procedure (735 ILCS 5/2-1202 (West 2010)). Under section 2-1202(b), [r]elief desired after trial in jury cases *** must be sought in a single post-trial motion.”
People v. Washington, 665 N.E.2d 1330 (Ill. 1996). “See 735 ILCS 5/2-1202(c) (West 1992) (allowing such claims to be made in a motion for a new trial within 30 days); 735 ILCS 5/2-1401(c) (West 1992) (permitting such claims up to two years after a final judgment, the period being excused in certain limited situations, including…”
Inman v. Howe Freightways, Inc., 2022 IL App (1st) 210274 (Ill. App. Ct. 2022). “Under section 2- 1202(b) (735 ILCS 5/2-1202(b) (West 2010)), “[r]elief desired after trial in jury cases, *** must be sought in a single post-trial motion.”
Johnson v. Target Stores, Inc., 791 N.E.2d 1206 (Ill. App. Ct. 2003). “As plaintiff notes, Supreme Court Rule 303(a)(1) provides that a notice of appeal must be filed "within 30 days after the entry of the final judgment appealed from, or, if a timely post-trial motion directed against the judgment is filed, * * * within 30 days after the entry of…”
Berg v. Allied Sec., Inc., Chicago, 697 N.E.2d 769 (Ill. App. Ct. 1998). “735 ILCS 5/2-1202 (West 1994) (formerly Ill.”
Kingbrook, Inc. v. Pupurs, 779 N.E.2d 867 (Ill. 2002). “Section 2-1202(b) provides in part: "Relief desired after trial in jury cases, heretofore sought by reserved motions for directed verdict or motions for judgment notwithstanding the verdict, in arrest of judgment or for new trial, must be sought in a single post-trial motion.”
Arient v. Shaik, 2015 IL App (1st) 133969 (Ill. App. Ct. 2015). “” 735 ILCS 5/2-1202(b), (c) (West 2012). ¶ 25 Section 2-1202(e) specifies what happens if a party in a jury case fails to file a posttrial motion.”
Blue v. Env't Eng'g, Inc., 828 N.E.2d 1128 (Ill. 2005). “However, Browning does not argue on appeal that the jury verdict should have been vacated on this basis, nor did Browning file any posttrial motion attacking the verdict on this basis.”
Choate v. Indiana Harbor Belt R.R. Co., 2012 IL 112948 (Ill. 2012). “2 ¶ 18 Defendants timely filed a posttrial motion pursuant to section 2-1202(b) of the Code of Civil Procedure (735 ILCS 5/2-1202(b) (West 2002)). Defendants requested a judgment non obstante veredicto (n.”
Garcia v. Seneca Nursing Home, 956 N.E.2d 1005 (Ill. App. Ct. 2011). “¶ 19 Posttrial motions in jury cases are governed by section 2-1202 of the Code of Civil Procedure (735 ILCS 5/2-1202 (West 2010)). Under section 2-1202(b), [r]elief desired after trial in jury cases * * * must be sought in a single post-trial motion.”
— 735 ILCS 5/2-1202(a) — 7 cases
Blockmon v. McClellan, 2019 IL App (1st) 180420 (Ill. App. Ct. 2019).
4220 Kildare, LLC v. Regent Ins. Co., 2020 IL App (1st) 181840 (Ill. App. Ct. 2020).
Hamilton v. Hastings, 2014 IL App (4th) 131021 (Ill. App. Ct. 2014).
Hamilton v. Hastings, 2014 IL App (4th) 131021 (Ill. App. Ct. 2014).
4220 Kildare, LLC v. Regent Ins. Co., 2020 IL App (1st) 181840 (Ill. App. Ct. 2020).
— 735 ILCS 5/2-1202(b) — 35 cases
Jacobs v. Yellow Cab Affiliation, Inc., 2017 IL App (1st) 151107 (Ill. App. Ct. 2017). “Subsequently, pursuant to the rules governing appeals, “A party may not urge as error on review of the ruling on the party’s post-trial motion any point, ground, or relief not specified in the motion.” Ill. S. Ct. R.”
Kingbrook, Inc. v. Pupurs, 779 N.E.2d 867 (Ill. 2002). “Section 2-1202(b) provides in part: "Relief desired after trial in jury cases, heretofore sought by reserved motions for directed verdict or motions for judgment notwithstanding the verdict, in arrest of judgment or for new trial, must be sought in a single post-trial motion.”
Choate v. Indiana Harbor Belt R.R. Co., 2012 IL 112948 (Ill. 2012). “2 ¶ 18 Defendants timely filed a posttrial motion pursuant to section 2-1202(b) of the Code of Civil Procedure (735 ILCS 5/2-1202(b) (West 2002)). Defendants requested a judgment non obstante veredicto (n.”
Harris v. Thompson, 2012 IL 112525 (Ill. 2012).
Inman v. Howe Freightways, Inc., 2022 IL App (1st) 210274 (Ill. App. Ct. 2022). “Under section 2- 1202(b) (735 ILCS 5/2-1202(b) (West 2010)), “[r]elief desired after trial in jury cases, *** must be sought in a single post-trial motion.”
— 735 ILCS 5/2-1202(c) — 35 cases
People v. Washington, 665 N.E.2d 1330 (Ill. 1996). “See 735 ILCS 5/2-1202(c) (West 1992) (allowing such claims to be made in a motion for a new trial within 30 days); 735 ILCS 5/2-1401(c) (West 1992) (permitting such claims up to two years after a final judgment, the period being excused in certain limited situations, including…”
Jacobs v. Yellow Cab Affiliation, Inc., 2017 IL App (1st) 151107 (Ill. App. Ct. 2017). “Subsequently, pursuant to the rules governing appeals, “A party may not urge as error on review of the ruling on the party’s post-trial motion any point, ground, or relief not specified in the motion.” Ill. S. Ct. R.”
Johnson v. Target Stores, Inc., 791 N.E.2d 1206 (Ill. App. Ct. 2003). “As plaintiff notes, Supreme Court Rule 303(a)(1) provides that a notice of appeal must be filed "within 30 days after the entry of the final judgment appealed from, or, if a timely post-trial motion directed against the judgment is filed, * * * within 30 days after the entry of…”
Rocha v. FedEx Corp., 2020 IL App (1st) 190041 (Ill. App. Ct. 2021).
Garcia v. Seneca Nursing Home, 2011 IL App (1st) 103085 (Ill. App. Ct. 2011). “¶ 19 Posttrial motions in jury cases are governed by section 2-1202 of the Code of Civil Procedure (735 ILCS 5/2-1202 (West 2010)). Under section 2-1202(b), [r]elief desired after trial in jury cases *** must be sought in a single post-trial motion.”
— 735 ILCS 5/2-1202(d) — 10 cases
Jacobs v. Yellow Cab Affiliation, Inc., 2017 IL App (1st) 151107 (Ill. App. Ct. 2017). “Subsequently, pursuant to the rules governing appeals, “A party may not urge as error on review of the ruling on the party’s post-trial motion any point, ground, or relief not specified in the motion.” Ill. S. Ct. R.”
Joseph T. Ryerson & Son, Inc. v. Travelers Indem. Co. of Am., 2020 IL App (1st) 182491 (Ill. App. Ct. 2021).
Berg v. Allied Sec., Inc., Chicago, 697 N.E.2d 769 (Ill. App. Ct. 1998). “735 ILCS 5/2-1202 (West 1994) (formerly Ill.”
Villa DuBois, LLC v. El, 2020 IL App (1st) 190182 (Ill. App. Ct. 2020).
Joseph T. Ryerson & Son, Inc. v. Travelers Indem. Co. of Am., 2020 IL App (1st) 182491 (Ill. App. Ct. 2021).
— 735 ILCS 5/2-1202(e) — 12 cases
Arient v. Shaik, 2015 IL App (1st) 133969 (Ill. App. Ct. 2015). “” 735 ILCS 5/2-1202(b), (c) (West 2012). ¶ 25 Section 2-1202(e) specifies what happens if a party in a jury case fails to file a posttrial motion.”
Crim v. Dietrich, 2020 IL 124318 (Ill. 2020). “735 ILCS 5/2-1202 (West 2016). 1 Therefore, according to defendant, the circuit court was barred from relitigating the jury’s verdict.”
Garcia v. Seneca Nursing Home, 2011 IL App (1st) 103085 (Ill. App. Ct. 2011). “¶ 19 Posttrial motions in jury cases are governed by section 2-1202 of the Code of Civil Procedure (735 ILCS 5/2-1202 (West 2010)). Under section 2-1202(b), [r]elief desired after trial in jury cases *** must be sought in a single post-trial motion.”
Arient v. Shaik, 2015 IL App (1st) 133969 (Ill. App. Ct. 2015).
Passafiume v. Jurak, 2023 IL App (3d) 220232 (Ill. App. Ct. 2023).
— 735 ILCS 5/2-1202(f) — 13 cases
Garcia v. Seneca Nursing Home, 2011 IL App (1st) 103085 (Ill. App. Ct. 2011). “¶ 19 Posttrial motions in jury cases are governed by section 2-1202 of the Code of Civil Procedure (735 ILCS 5/2-1202 (West 2010)). Under section 2-1202(b), [r]elief desired after trial in jury cases *** must be sought in a single post-trial motion.”
Longnecker v. Loyola Univ. Med. Ctr., 891 N.E.2d 954 (Ill. App. Ct. 2008).
Ramsey v. Morrison, 676 N.E.2d 1304 (Ill. 1997).
Crystal Lake Ltd. P'ship v. Baird & Warner Residential Sales, Inc., 2018 IL App (2d) 170714 (Ill. App. Ct. 2018).
Rosolowski v. Clark Refining & Mktg., 890 N.E.2d 1011 (Ill. App. Ct. 2008).
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