Nebraska Revised Statutes

Neb. Rev. Stat. § 25-1315.02 (2026)

Motion for directed verdict at close of evidence; effect; filing before entry of judgment; treatment; motion to set aside verdict or judgment; power of court

✓ current as of July 2026
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Whenever a motion for a directed verdict made at the close of all the evidence is denied or for any reason is not granted, the court is deemed to have submitted the action to the jury subject to a later determination of the legal questions raised by the motion. No later than ten days after the entry of judgment, a party who has moved for a directed verdict may move to have the verdict and any judgment entered thereon set aside and to have judgment entered in accordance with the moving party's motion for a directed verdict. If the motion is filed after the announcement of a verdict but before the entry of judgment, it shall be treated as filed after the entry of judgment and on the day thereof. If a verdict is not returned, within ten days after the jury is discharged a party who has moved for a directed verdict may move for judgment in accordance with the moving party's motion for a directed verdict. A motion for a new trial may be joined with this motion, or a new trial may be prayed for in the alternative. If judgment was entered, the court may allow the judgment to stand or may reopen the judgment and either order a new trial or direct the entry of judgment as if the requested verdict had been directed. If no verdict was returned, the court may direct the entry of judgment as if the requested verdict had been directed or may order a new trial.

Notes of Decisions
Cited in 70 cases (3 in the last 5 years), 1948–2025 · leading case: Krepcik v. Interstate Transit Lines, 43 N.W.2d 609 (Neb. 1950).
Krepcik v. Interstate Transit Lines, 43 N.W.2d 609 (Neb. 1950). · cites it 26× “" § 25-1315.02, R.R.S.1943. "An order entering judgment as provided in section 25-1315.”
McEwen v. Nebraska State Coll. Sys., 303 Neb. 552 (Neb. 2019). · cites it 2× “25 See Neb. Rev. Stat. § 25-1315.02 (Reissue 2016).”
Snyder Ex Rel. Snyder v. Contemporary Obstetrics & Gynecology, P.C., 605 N.W.2d 782 (Neb. 2000). · cites it 8× “The defendants filed posttrial motions for judgment notwithstanding the verdict, pursuant to Neb.Rev.Stat. § 25-1315.02 (Reissue 1995).”
Khaitov v. Greater Omaha Packing Co., 319 Neb. 932 (Neb. 2025). · cites it 24× “The plain language of Neb. Rev. Stat. § 25-1315.02 (Reissue 2016) makes it wholly unneces- sary for a trial court to expressly reserve the decision on a motion for directed verdict made at the close of all the evidence, because the statute makes the reservation automatic,…”
Ditloff v. Otto, 476 N.W.2d 675 (Neb. 1991). · cites it 13× “Otto then filed a motion pursuant to Neb. Rev. Stat. § 25-1315.02 (Reissue 1989), which provides in pertinent part: Whenever a motion for a directed verdict made at the close of all the evidence is denied or for any reason is not granted, the court is deemed to have submitted…”
State Ex Rel. Serrano v. Bellamy, 652 N.W.2d 86 (Neb. 2002). · cites it 2× “2000), or a motion to set aside a verdict or judgment under Neb. Rev. Stat. § 25-1315.02 (Cum. Supp. 2000).”
132 Ventures v. Active Spine Physical Therapy, 318 Neb. 64 (Neb. 2024). · cites it 5× “10 [8] A trial court cannot commit error in resolving an issue never presented and submitted to it for disposition.”
Dunn v. Hemberger, 430 N.W.2d 516 (Neb. 1988). · cites it 8× “Neb. Rev. Stat. § 25-1315.02 (Reissue 1985) authorizes entry of a judgment n.”
Hamilton v. Bares, 678 N.W.2d 74 (Neb. 2004). · cites it 2× “ASSIGNMENTS OF ERROR Bares asserts that the district court erred in overruling his motions for directed verdict, for new trial, and for judgment notwithstanding the verdict.”
State v. Bao, 690 N.W.2d 618 (Neb. 2005). · cites it 2× “01, (b) by a timely motion to alter or amend a judgment under section 25-1329, or (c) by a timely motion to set aside the verdict or judgment under section 25-1315.02, and the full time for appeal fixed in subsection (1) of this section commences to run from the entry of the…”
State v. Spotted Elk, 420 N.W.2d 707 (Neb. 1988). · cites it 5× “§ 25-1143 (Reissue 1985), within 10 days after the “decision was rendered”; or making a motion for judgment notwithstanding the verdict, pursuant to Neb. Rev. Stat. § 25-1315.02 (Reissue 1985), within 10 days of receipt of the verdict.”
Munstermann v. Alegent Health-Immanuel Med. Ctr., 716 N.W.2d 73 (Neb. 2006). · cites it 2× “See Neb. Rev. Stat. § 25-1315.02 (Cum. Supp. 2004).”
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