Understanding Summary Judgment Motions in Lawsuits

If you or your business are in a lawsuit, one of the most important phases of the litigation for you to understand is when it comes time for Summary Judgment motions. A quick side note, not all lawsuits will have these types of motions. If there are many issues of fact that would need to be decided by a judge or jury at a trial, then there's a good chance that you won't see this type of motion in your case.

But it's also common that each side is convinced that they have all the facts on their side and that they should be granted Summary Judgment, and will make a motion even when it may not be warranted. These motions can be used as bargaining chips for settlement and you should understand what they are and how they can impact your lawsuit, preferably before you even get involved in the case.

What Is Summary Judgment?

Summary Judgment happens when a judge decides a specific issue, sometimes the entire case, and that decision doesn't require a full trial. When they make this decision, it's based on the evidence presented by both parties and is granted only when there are no "genuine disputes over material facts." If that's the case, the judge applies the law to those undisputed facts and determines which party is entitled to judgment as a matter of law.

Imagine a car accident case where there's video that clearly shows one party running a red light and causing the accident. If no other facts are in dispute, the judge may grant summary judgment in favor of the injured party on the issue of liability, eliminating the need for a trial on that matter.

The essence of summary judgment lies in efficiency—it avoids unnecessary trials when the facts are clear and undisputed. However, if there are factual disagreements that require further examination, the case will proceed to trial.

The Role of Summary Judgment in Litigation

Summary judgment motions can be filed by either party in a lawsuit—the plaintiff or the defendant. These motions are often strategic tools used to streamline litigation or even end it entirely:

Defendants frequently file for summary judgment to have the case dismissed before trial. For example, in medical malpractice cases, a defendant might argue that no reasonable jury could find them negligent based on the evidence.
Plaintiffs may also file for summary judgment to secure a favorable ruling on liability or other key issues without going through a full trial.
In many cases, both parties will file competing motions for summary judgment. This creates what is often described as a "mini-trial," where the judge evaluates evidence and arguments from both sides to resolve specific issues before trial.

The Summary Judgment Process

The process for filing and deciding summary judgment motions generally follows these steps:

Motion Filed: One party submits their motion for summary judgment, accompanied by evidence such as contracts, payment records, deposition transcripts, expert reports, and sworn affidavits.
Opposition Response: The opposing party files their response, often arguing that disputed facts exist and that summary judgment is inappropriate.
Reply Brief: The original movant may file a reply to address points raised in the opposition.
Oral Argument: The court may schedule a hearing where attorneys present their arguments regarding the motion.
Judge Decides: The judge reviews all submissions and issues a ruling.

The exact procedures and timelines for summary judgment motions vary by jurisdiction and even by individual judges. Some courts may allow appeals of partial summary judgments (decisions resolving only certain issues), while others require all issues to be resolved before an appeal can be filed.

Evidence in Summary Judgment

Unlike trials, where witnesses testify live before a jury or judge, evidence in summary judgment motions is presented in written form. This includes:

- Sworn affidavits or declarations
- Deposition transcripts
- Documents such as contracts or emails
- Expert opinions

The judge evaluates this evidence to determine whether any genuine disputes over material facts exist. If reasonable jurors could disagree on key issues based on the evidence presented, summary judgment will likely be denied.

Why Summary Judgment Matters

Summary judgment motions can dramatically alter the trajectory of a lawsuit:

Time and Cost Savings: By resolving disputes early, summary judgments save both parties significant time and legal expenses associated with preparing for trial.
Case Resolution: A favorable ruling on summary judgment can end litigation entirely or narrow down the issues that need to be addressed at trial.
Settlement Leverage: Pending summary judgment motions often create uncertainty for both sides, encouraging settlement discussions. For instance, if a defendant’s motion is denied, they may opt to settle rather than face trial risks. If granted, it could pressure plaintiffs to accept reduced settlements.

Challenges in Opposing Summary Judgment

When faced with an opposing party's motion for summary judgment, attorneys often argue that factual disputes exist requiring resolution at trial. Common strategies include:

- Highlighting inconsistencies in evidence
- Presenting alternative interpretations of events
- Demonstrating that additional testimony or discovery is needed

Judges are generally cautious about granting summary judgments when there’s any ambiguity about material facts because doing so could deny one party their right to present their case fully at trial.

Partial vs. Full Summary Judgment

It’s important to note that judges can grant partial summary judgments. This means they resolve certain claims or issues while leaving others for trial. For example:

- In a breach of contract case, a judge might rule on liability but leave damages unresolved.
- In personal injury cases involving multiple claims (e.g., negligence and product liability), some claims may be dismissed while others proceed.

Partial summary judgments simplify trials by narrowing down what needs to be litigated.

Key Considerations for Businesses

For businesses involved in lawsuits, understanding and preparing for potential summary judgment motions is essential:

Legal Representation: Businesses must hire attorneys to represent them; self-representation is not permitted unless you’re an attorney yourself.
Strategic Planning: Allocate time and resources early in your litigation plan for handling summary judgment motions.
Evidence Preparation: Work closely with your legal team to gather relevant documents and testimony well before filing deadlines.
Settlement Opportunities: Be prepared for settlement discussions during this phase as both sides assess their chances of success.

Summary judgment motions are powerful tools that can resolve lawsuits efficiently by eliminating unnecessary trials when facts are undisputed. Whether you’re seeking or opposing such a motion, having experienced legal counsel is crucial to navigate this complex process effectively. By understanding how summary judgments work—and their potential impact—you’ll be better equipped to manage your case strategically and protect your interests throughout litigation.

Do I Need an Attorney for my Lawsuit?

If you're involved in a lawsuit and things seem to be getting a bit overwhelming, let's schedule a Legal Strategy Session online or by calling my Edina, Minnesota office at (612) 294-6982 or my New York City office at (646) 847-3560. My office will be happy to find a convenient time for us to have a phone call to review the best options and next steps for you and your business.