Dupree v. Younger, 598 U.S. 729

Younger, a pretrial detainee in Maryland, alleged three corrections officers assaulted him at Dupree's order and sued under 42 U.S.C. § 1983 for excessive force.
Dupree moved for summary judgment asserting Younger failed to exhaust administrative remedies under the PLRA (42 U.S.C. § 1997e(a)).
The District Court denied summary judgment, noting factual disputes about exhaustion but concluding Maryland’s internal investigation satisfied exhaustion.
At trial Dupree did not introduce evidence on exhaustion, did not press the issue in a Rule 50(a) motion, and did not file a post-trial Rule 50(b) renewed motion; the jury returned a $700,000 verdict for Younger.
On appeal Dupree challenged only the District Court’s summary-judgment ruling on exhaustion; the Fourth Circuit dismissed the appeal under its precedent that issues denied at summary judgment must be renewed post-trial to preserve appellate review.
The Supreme Court granted certiorari to resolve the circuit split over whether a post-trial Rule 50 motion is required to preserve a purely legal issue decided at summary judgment.

Issue	Plaintiff's Argument (Younger)	Defendant's Argument (Dupree)	Held
Whether a Rule 50(b) post-trial motion is required to preserve for appeal a purely legal issue decided against a party at summary judgment	Ortiz controls: any denial of summary judgment is not reviewable after trial; post-trial motion required	A purely legal ruling at summary judgment is not superseded by trial and is preserved for appeal without renewing in Rule 50(b)	A Rule 50(b) post-trial motion is not required to preserve a purely legal issue decided at summary judgment; remand to determine whether the issue here is purely legal

Ortiz v. Jordan, 562 U.S. 180 (2011) (denial of summary judgment on sufficiency-of-the-evidence grounds is unreviewable after trial; post-trial renewal required for factual sufficiency claims)
Quackenbush v. Allstate Ins. Co., 517 U.S. 706 (1996) (final judgment deferred review of interlocutory rulings; appeal of final judgment opens record)
Varghese v. Honeywell Int'l, Inc., 424 F.3d 411 (4th Cir. 2005) (Fourth Circuit precedent requiring post-trial renewal for issues denied at summary judgment)
Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc., 574 U.S. 318 (2015) (appellate courts can and do separate legal from factual matters)
Unitherm Food Sys., Inc. v. Swift-Eckrich, Inc., 546 U.S. 394 (2006) (appellate review presupposes the lower court had first opportunity to consider the argument)
Cone v. West Virginia Pulp & Paper Co., 330 U.S. 212 (1947) (trial judge’s firsthand view of witnesses matters for factual determinations)
Mitchell v. Forsyth, 472 U.S. 511 (1985) (some interlocutory orders, e.g., qualified immunity denials, are immediately appealable)