[COURT NAME]

STATE OF LOUISIANA

PARISH OF [PARISH]

[PLAINTIFF NAME], §
Plaintiff § DOCKET NO. [DOCKET NO.]
v. §
§ DIVISION “[DIV.]”
[DEFENDANT NAME], §
Defendant §

MOTION FOR SUMMARY JUDGMENT

[// GUIDANCE: This template integrates all components customarily filed in support of a Louisiana motion for summary judgment: (1) the motion; (2) a supporting memorandum; (3) a separate statement of uncontested material facts; (4) a proposed order; and (5) a certificate of service. Delete or add sections to conform to local standing orders or judge-specific preferences.]

I. MOTION

NOW INTO COURT, through undersigned counsel and pursuant to La. Code Civ. Proc. arts. 966–967 and Uniform Rules for Louisiana District Courts (“URDC”) Rule 9.10, comes [MOVER NAME] (“Mover”), who respectfully moves this Honorable Court for entry of summary judgment in its favor and against [NON-MOVER NAME] (“Non-Mover”) on the grounds that there is no genuine issue as to any material fact and Mover is entitled to judgment as a matter of law.

In further support, Mover submits the attached:

1. Memorandum in Support of Motion for Summary Judgment;
2. Statement of Uncontested Material Facts (“SUMF”) with pinpoint citations to record evidence;
3. Exhibits [A–__] as identified in the SUMF; and
4. Proposed Order.

WHEREFORE, Mover prays that this Motion be set for hearing on [HEARING DATE] at [TIME] a.m./p.m., or on a date otherwise fixed by the Court; that summary judgment be rendered herein in favor of Mover and against Non-Mover; and for all general and equitable relief to which Mover is justly entitled.

Respectfully submitted,

text

[ATTORNEY NAME] (Bar No. [####])
[LAW FIRM NAME]
[Street Address]
[City, State ZIP]
Telephone: ([###]) ###-####
Email: [[email protected]]
Counsel for [MOVER NAME]

II. NOTICE OF HEARING

PLEASE TAKE NOTICE that undersigned counsel will present the foregoing Motion for Summary Judgment for hearing before the Honorable [JUDGE NAME], Division “[DIV.]”, on the ___ day of ____, 20__, at [Time] a.m./p.m., or at such other time as may be set by the Court.

III. MEMORANDUM IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT

A. Introduction

This dispute arises from [succinct case synopsis no more than 2–3 sentences]. After adequate discovery, the material facts are not in genuine dispute, and the law compels judgment in Mover’s favor.

B. Statement of the Case and Procedural Posture

[Brief chronology: petition/answer, key motions, discovery cut-off, current trial date.]

C. Standard of Review

Under La. Code Civ. Proc. art. 966(A)(3), summary judgment “shall be rendered forthwith if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to material fact and that the mover is entitled to judgment as a matter of law.” The moving party bears the initial burden of proof. Once satisfied, the burden shifts to the adverse party to produce factual evidence sufficient to establish the existence of a genuine issue. La. Code Civ. Proc. art. 966(D)(1). Evidence may include only those materials listed in art. 966(A)(4) and must be admissible.

D. Statement of Uncontested Material Facts

Mover’s Statement of Uncontested Material Facts is filed concurrently herewith in compliance with art. 966(B)(2). Each fact is supported by a specific record citation.

E. Argument

[// GUIDANCE: Break into numbered sections that track each independent legal theory or claim element. Example below.]

1. Mover’s prima facie case is established as a matter of law.
   a. [Quote/describe governing statute or contract provision].
   b. [Apply undisputed fact # 1–# n to legal elements.]

2. Non-Mover cannot meet its evidentiary burden to show a genuine issue.
   a. [Discuss absence of contrary evidence.]
   b. [Address any affirmative defenses.]

3. [Alternative/Additional Grounds]
   [E.g., prescription, peremption, procedural bar.]

F. Conclusion

For the foregoing reasons, and pursuant to La. Code Civ. Proc. arts. 966–967, Mover respectfully requests that this Court grant the Motion for Summary Judgment and enter judgment in the form attached hereto.

IV. STATEMENT OF UNCONTESTED MATERIAL FACTS

[pursuant to La. Code Civ. Proc. art. 966(B)(2)]

[// GUIDANCE: Every fact must be concise, separately numbered, and tied to competent evidence. Avoid argument.]

V. PROPOSED ORDER

text
STATE OF LOUISIANA §
PARISH OF [PARISH] §
§
DISTRICT COURT § DOCKET NO. [DOCKET NO.]
§ DIVISION “[DIV.]”
ORDER
Considering the foregoing Motion for Summary Judgment, the Memorandum in Support, the Statement of Uncontested Material Facts, the evidence of record, the arguments of counsel, and the law applicable,

IT IS ORDERED, ADJUDGED, AND DECREED that the Motion for Summary Judgment filed by [MOVER NAME] be and is hereby GRANTED. Judgment is rendered in favor of [MOVER NAME] and against [NON-MOVER NAME] as follows:

[Precisely state relief—e.g., dismissal with prejudice, specific monetary award, declaratory relief.]

THUS SIGNED in [City], Louisiana, this ___ day of ____, 20__.

JUDGE [JUDGE NAME]
[__] th Judicial District Court, Parish of [PARISH]

VI. CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Motion for Summary Judgment, Memorandum in Support, Statement of Uncontested Material Facts, and Proposed Order were served on all counsel of record via [method—e.g., e-mail, U.S. mail, hand delivery, or electronic filing] this ___ day of ____, 20__.

text

[ATTORNEY NAME]

APPENDIX A

Checklist of Key Louisiana Requirements

1. Filing Deadline: Motion must be filed and served at least 65 days before the scheduled trial date unless the court sets a different deadline. La. Code Civ. Proc. art. 966(B)(1).
2. Page Limit: Principal memorandum not to exceed 25 pages without court permission. URDC Rule 9.10(b).
3. Separate SUMF: Required; must include pinpoint citations. Art. 966(B)(2).
4. Evidence: Limited to pleadings, depositions, answers to interrogatories, admissions, affidavits, certified medical records, written stipulations, and any documents specifically allowed by statute. Art. 966(A)(4).
5. Hearing Date & Notice: Coordinate with clerk; provide written notice to all parties.
6. Signature Compliance: Every filing must be signed in accordance with La. Code Civ. Proc. art. 863 and URDC Rule 9.9.

[// GUIDANCE: Remove Appendix A if local rules prohibit inclusion of checklists or practice notes in pleadings.]