What is the test for overturning a jury verdict for insufficient evidence?

As the majority rightly notes, overturning a jury verdict for insufficient evidence should only occur on the rarest of occasions, in which there is a "complete absence of evidence." Op. at 171 (quoting Luciano v. Olsten Corp. , 110 F.3d 210, 214 (2d Cir. 1997) ). We should exercise our discretion to overturn a jury verdict even more cautiously if we do so on grounds not raised when the verdict winner still had an opportunity to supplement the record. This hesitancy is especially important when the verdict winner is a pro se litigant because individuals unfamiliar with the intricacies of our legal system stand to benefit the most from being put on notice as to any deficiencies of proof. Moreover, because a directed verdict based on grounds not raised in a pre-verdict motion deprives the non-movant of the opportunity to cure the

[895 F.3d 178]