At the close of the evidence, First National Bank renewed its motion for a judgment as a matter of law. The trial court indicated that the motion was still under advisement. The jury found that First National Bank had breached the account agreement, had been negligent in performing its duties to Appellants, and had breached its fiduciary duties to Appellants. First National Bank again renewed its motion for a judgment as a matter of law. After a hearing on the motion, the trial court granted First National Bank's motion, set aside the jury's verdict, and dismissed Appellants' complaint.
Appellants appeal from that decision.
Thus, when the case is allowed to go to the jury and the jury renders a verdict which is not supported by legally sufficient evidence, the trial court has an obligation to direct the entry of judgment as a matter of law. This obligation must be fulfilled despite the fact that judgment as a matter of law should be granted cautiously and sparingly. First National Bank argues that Appellants' claims were barred under Wyo. This statute placed an absolute time limit of one year on a customer's right to make a claim for the payment of an instrument which contained an unauthorized signature. The one-year limitation period was not merely a limitation but was a rule of substantive law which barred absolutely a customer's untimely asserted right to make a claim against the bank.