Pratt v. Vencor, Inc.

Opinion

WISEMAN, J.

This case is like a bottle of fine California Chardonnay— very dry. It addresses a purely procedural question of the “trigger date” for the commencement of the 60-day time period within which the court must rule on a motion for judgment notwithstanding the verdict (JNOV) when there is no corresponding motion for a new trial. We publish to resolve the contention that there is ambiguity in the language of Code of Civil Procedure sections 629 and 660 1 in determining the latest date for ruling on a JNOV motion.

We hold, pursuant to sections 629 and 660, that where there is no…