Dupree v. Younger (1983 Post-Trial Motion)

Supreme Court Decision Syllabus (SCOTUS Podcast)

In Dupree v. Younger, the Supreme Court addressed whether a post-trial motion of a purely legal issue that was resolved at summary judgment, requires a post-trial motion to be preserved on appeal. Kevin Younger sued Neil Dupree, who was a correctional officer under Section 1983. Dupree moved for summary judgment alleging that Younger had failed to exhaust administrative remedies. The district court denied the motion. After Younger prevailed at trial by obtaining $700,000 in damages, Dupree appealed alleging the district court improperly dismissed the suit. Under Fourth Circuit precedent, that court ruled against Younger reasoning that he was required to file a Rule 50 post-trial motion to preserve the issue on appeal. The Supreme Court reversed, finding that pure questions of law resolved in summary judgment do not require a post-trial motion to preserve the issue for appeal. The Court writes in the syllabus: "And it makes sense: Factual development at trial will not change the district court’s pretrial answer to a purely legal question, so a post-trial motion requirement would amount to an empty exercise." Read by Jake Leahy.