## Facts

- A Maryland pretrial detainee, Kevin Younger, sued correctional officer lieutenant Neil Dupree and others under 42 U.S.C. § 1983, alleging Dupree ordered guards to assault him, violating the Fourteenth Amendment.
- Dupree moved for summary judgment, arguing Younger failed to exhaust administrative remedies under the Prison Litigation Reform Act (PLRA).
- The district court denied summary judgment, reasoning that the prison’s internal investigation satisfied any exhaustion requirement.
- At trial, Dupree did not present evidence on the PLRA exhaustion defense.
- The jury found Dupree and co-defendants liable and awarded Younger $700,000.
- Dupree did not file a renewed motion for judgment as a matter of law under Federal Rule of Civil Procedure 50(b) and appealed only the district court’s rejection of his PLRA exhaustion defense.
- The Fourth Circuit dismissed the appeal under circuit precedent requiring any summary-judgment-rejected claim or defense to be renewed post-trial to be preserved for appeal.

## Issues

1. Must a party file a post-trial motion under Federal Rule of Civil Procedure 50 to preserve for appellate review a purely legal issue rejected at summary judgment?

## Decision

- The Supreme Court unanimously vacated the Fourth Circuit’s judgment and remanded.
- A post-trial Rule 50 motion is not required to preserve for appellate review a purely legal issue resolved at summary judgment.
- The Court did not decide whether Dupree’s PLRA exhaustion argument was “purely legal,” leaving that determination to the Fourth Circuit on remand.

## Legal Principles

- Rule 50(b) preservation is required for sufficiency-of-the-evidence challenges after trial because the trial record supersedes the summary-judgment record.
- Purely legal rulings at summary judgment are not superseded by the trial record and merge into the final judgment, making them reviewable on appeal without a Rule 50(b) motion.
- Requiring a Rule 50(b) motion for purely legal issues serves no meaningful purpose because trial proceedings do not alter the legal analysis already decided pretrial.
- A categorical rule requiring post-trial renewal of every issue rejected at summary judgment is incorrect because it fails to distinguish factual sufficiency questions from purely legal questions.

## Conclusion

The Court held that litigants may appeal a district court’s summary-judgment resolution of a purely legal issue without filing a Rule 50(b) post-trial motion, and it remanded for the court of appeals to determine whether the asserted PLRA exhaustion issue qualified as purely legal.


Dupree v. Younger, 598 U.S. 729 (2023)