Slaughter, J.
After a plaintiff rests his case, the trial court may enter a directed verdict (or judgment on the evidence) against him if there is insufficient evidence on any element of his prima facie case. We reaffirmed this standard in Purcell v. Old National Bank, 972 N.E.2d 835 (Ind. 2012). There, we held a trial court may review evidence both quantitatively and qualitatively. But this standard left open a question we must resolve today—whether a court may take on the jury’s fact-finding role to weigh evidence and assess witness credibility at the close of the plaintiff’s case. We hold that at the directed-verdict stage, the court can review whether inferences from the evidence are reasonable, but it cannot weigh conflicting evidence or assess witness credibility. To do otherwise would deprive the plaintiff of his constitutional right to a jury trial. Applying this standard here, we hold the trial court erred in directing the verdict for defendant Erie Insurance Exchange, but we affirm the directed verdict for defendant Churilla Insurance.
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Here, we hold that the trial court erred in granting judgment on the evidence to Erie because the Cosmes’ case-in-chief presented sufficient (though conflicting) evidence to prove Erie breached its contract and violated its duty of good faith. But the court correctly granted judgment to Churilla because the evidence showed Churilla owed no special duty to the Cosmes to procure insurance or advise on the insurance policy.
Under Purcell, we analyze Rule 50(A) motions both quantitatively and qualitatively. Evidence fails quantitatively if no evidence supports finding for the nonmovant (the any-evidence standard). Id. at 840. Evidence fails qualitatively if the probative evidence cannot create a reasonable inference that a jury could find for the nonmovant (the substantial-evidence standard). Ibid. A nonmovant—usually a plaintiff—may fail the qualitative prong “either because of an absence of credibility of a witness or because the intended inference may not be drawn therefrom without undue speculation.” Ibid. (quoting Am. Optical Co. v. Weidenhamer, 457 N.E.2d 181, 184 (Ind. 1983)). When evaluating the evidence, the court must look at the evidence in the light most favorable to the nonmovant. Id. at 839.
On this point, Purcell is inconsistent in both promoting and simultaneously disavowing courts that would assess witness credibility and weigh evidence at the directed-verdict stage. The qualitative prong expressly permits the court to assess “an absence of credibility of a witness”. Id. at 840 (quoting Am. Optical Co., 457 N.E.2d at 184). It also implicitly permits the court to weigh evidence. The qualitative prong asks “not merely whether a conflict of evidence may exist, but rather whether there exists probative evidence, substantial enough to create a reasonable inference that the non-movant has met his burden.” Id. at 841. This suggests that a conflict of evidence would not defeat a directed-verdict motion and that a court must assess both the “probative” value of evidence and whether that evidence is “substantial”. Ibid.
In practice, Purcell’s analysis allows courts to weigh some of the evidence. There, we found a generalized, ambiguous interrogatory response insufficient to link the defendant to the alleged fraud. Id. at 841– 42. We also considered the conflicting evidence—testimony explaining the interrogatory response during trial that suggested the defendant was not tied to the fraud. Ibid. Thus, along with looking at the quality of the nonmovant’s evidence (what could be reasonably inferred from the evidence most favorable to the nonmovant), we also weighed the conflicting evidence not favorable to the nonmovant and found “as a whole” the evidence could not defeat the directed verdict. Id. at 841.
While permitting courts to assess witness credibility and weigh evidence in the qualitative prong, Purcell simultaneously instructs courts to refrain from either function: “It remains true that a court is not free to engage in the fact-finder’s function of weighing evidence or judging the credibility of witnesses to grant judgment on the evidence, where fair-minded men may reasonably come to competing conclusions.” Id. at 842. Indeed, Purcell says, this function “has always been within the purview of the jury.” Ibid.
Given Purcell’s contradictory commands, we clarify that courts may not weigh evidence or assess witness credibility—fact-finding functions reserved for the jury—at the close of plaintiff’s case-in-chief. This is why, historically, we have cautioned courts not to deprive juries of this role by granting directed verdicts. See, e.g., Whitaker v. Borntrager, 122 N.E.2d 734, 734–35 (Ind. 1954). This approach also aligns with our summary-judgment standard, which allows even a self-serving affidavit to defeat summary judgment so a case can go to trial. Hughley v. State, 15 N.E.3d 1000, 1004 (Ind. 2014). Only after both sides have rested and the jury returns its verdict do we permit the trial judge to take a more substantive role in assessing the evidence as a so-called thirteenth juror, empowering the court to conclude that no reasonable jury could have reached the result it did. Chi Yun Ho v. Frye, 880 N.E.2d 1192, 1196 (Ind. 2008). At the post-verdict stage, the court is not impeding the jury-trial right. And directing judgment after a jury verdict has a lower effect on judicial resources. If a trial court sets aside a jury verdict erroneously, the appellate court can reinstate the verdict. But if there is no jury verdict, the only suitable appellate remedy is a new trial.
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In sum, under our current standard, we permit courts to ensure the inferences supporting the nonmovant’s claims are reasonable, but courts cannot take on the jury’s fact-finding functions of weighing conflicting evidence and assessing witness credibility.
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While a trial court has no fact-finding role under Rule 50(A), the court may take a more active role after the jury has returned a verdict, or after the court has entered judgment. On a motion to correct error under Rule 59(J), a trial court shall grant a new trial if the jury’s verdict “is against the weight of the evidence”. T.R. 59(J)(7). And the court shall enter judgment notwithstanding the jury’s verdict if the verdict “is clearly erroneous as contrary to or not supported by the evidence”. Ibid. On a Rule 59(J) motion, the judge acts as the “thirteenth juror” and must “sift and weigh the evidence and judge witness credibility.” Chi Yun Ho, 880 N.E.2d at 1196 (quoting Keith v. Mendus, 661 N.E.2d 26, 31 (Ind. Ct. App. 1996)).
One reason we permit a more active role for the trial court after the jury has entered its verdict is because, on appeal, if the appellate court disagrees with the trial judge’s ruling under Rule 59(J), it can reinstate the jury’s verdict. At that stage, there is a verdict to reinstate. But on directed verdict, an appellate reversal requires a new trial before a different jury because the first jury never got to render a verdict—an unwise, inefficient use of judicial resources. An appellate court also can better review the merits of how a trial court weighed evidence at the Rule 59(J) stage because the court must detail its reasoning in a written order. When ordering a new trial, the trial court must both “specify the general reasons” for its ruling and “make special findings of fact upon each material issue or element of the claim”. T.R. 59(J). Rule 50(A) does not impose the same requirements.
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For these reasons, we reverse the trial court’s directed verdict for Erie, we affirm as to Churilla, and we remand for further proceedings consistent with our opinion.
Rush, C.J., and Massa, Goff, and Molter, JJ., concur