Judgment notwithstanding the verdict or JNOV is a practice in civil jury trials, where the judge overrules the decision of a jury and reverses or amends their verdict. The judge has discretion to avoid extreme and unreasonable jury decisions. However, a judge is not permitted to enter a JNOV of “guilty” following a jury acquittal because of the guaranteed right against double jeopardy. A JNOV is appropriate only if the judge determines that no reasonable jury could have reached the given verdict. Reversal of a jury's verdict by a judge occurs when the judge believes that there were insufficient facts on which to base the jury's verdict, or that the verdict did not correctly apply the law. A JNOV is generally available to both plaintiffs and defendants, and an arrest of judgment is primarily used with judgments in criminal cases. A JNOV is proper when the court finds that the party bearing the burden of proof fails to make out a prima facie case (a case that on first appearance will prevail unless contradicted by evidence).