A motion for summary judgment argues that, based on the evidence already in the record, there's no genuine dispute of material fact left — meaning the court can decide the case (or part of it) as a matter of law, without a trial.
The standard is stricter than it sounds
'No genuine dispute of material fact' doesn't mean no disagreement at all — it means no dispute that a reasonable jury could resolve either way. Courts view the evidence in the light most favorable to the non-moving party, which makes this a high bar.
Build the motion around the evidentiary record
Every factual assertion needs a citation to the record — deposition testimony, admissions, discovery responses. A summary judgment motion is won or lost on what the evidence actually shows, not on argument alone.
A statement of undisputed facts does real work
Most jurisdictions require a separate, numbered statement of undisputed material facts. Drafting it carefully — specific, evidence-backed, hard to dispute — forces the opposing party to either concede points or manufacture a dispute that may not hold up.
Anticipate the response
A strong motion addresses the obvious counterarguments before the other side raises them, rather than leaving gaps for the opposition's response to exploit.
Partial summary judgment is often underused
Even when the whole case can't be resolved this way, moving for summary judgment on specific claims or defenses can narrow what actually needs to go to trial — cutting cost and complexity even in a short-of-total win.