Criteria – Standards for Judgment – General

Criteria or standards for judgment are foundational principles in civil litigation, providing the threshold for resolving cases without a full trial. Through dispositive motions like summary judgment, default judgment, and judgment as a matter of law, courts evaluate whether a party is entitled to prevail as a matter of law or whether genuine disputes require trial. These standards, codified in statutes and procedural rules, promote judicial efficiency while protecting due process and the right to a trial on genuine factual disputes.

Criteria (for Judgment)

Criteria for judgment refer to the legal requirements and evidentiary thresholds that a party must satisfy to obtain a court ruling in their favor without a full trial. These criteria depend on the type of motion, such as summary judgment, default judgment, or judgment as a matter of law. They include proper procedural compliance, the burden of proof, and the sufficiency and admissibility of evidence. For instance, in default judgment (CPLR 3215), criteria include proof of service, the defendant’s failure to respond, and a factual basis for the claim. For summary judgment, the moving party must establish there is no genuine dispute of material fact and that they are entitled to judgment as a matter of law.

The criteria protect due process, ensure only meritorious cases proceed, and maintain judicial efficiency. In federal courts, criteria are articulated in the Federal Rules of Civil Procedure—most notably Rules 50 and 56.

Standard for Judgment

The standard for judgment is the substantive and procedural measure by which courts determine whether to grant dispositive relief. This varies by motion:

• Summary Judgment: No genuine dispute of material fact and entitlement to judgment as a matter of law (FRCP 56(a), CPLR 3212(b)).
• Default Judgment: Sufficient evidence of liability and damages, plus procedural compliance, upon the opposing party’s failure to respond (CPLR 3215, FRCP 55).
• Judgment as a Matter of Law: No legally sufficient evidentiary basis for a reasonable jury to find for the nonmovant (FRCP 50).

The standard determines the burden of proof, evidence required, and whether the court may bypass a jury. Courts also consider strict compliance with procedural requirements and, at times, the interests of justice.

Summary Judgment

Summary judgment is a pretrial motion allowing a court to resolve all or part of a lawsuit when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law. In New York, CPLR 3212 governs summary judgment; in federal court, FRCP 56 applies. The moving party must submit admissible evidence—affidavits, depositions, documentary proof—demonstrating there are no triable issues. The opposing party must respond with evidence creating a real factual dispute; mere denials or unsworn statements are insufficient.

Key aspects:

• Motion must generally be made after issue is joined and within specified deadlines.
• May be granted in whole or in part.
• Designed to weed out unmeritorious claims and focus trial on genuine disputes.

Default Judgment

Default judgment is granted when a party (typically the defendant) fails to appear, plead, or otherwise defend as required. Rules for default judgment are found in CPLR 3215 (New York) and FRCP 55 (federal). Requirements include:

• Proof of proper service.
• Evidence of the default.
• Proof of the claim’s validity.

If the claim is for a sum certain, the clerk may enter judgment. For unliquidated claims, the court holds an inquest to determine damages. Courts retain discretion to deny default judgment if procedural or substantive irregularities exist. Defendants can move to vacate default judgment by showing a reasonable excuse and a potentially meritorious defense.

Judgment as a Matter of Law (JMOL)

Judgment as a matter of law (JMOL), under FRCP 50, allows courts to resolve claims mid-trial or post-verdict when the evidence is insufficient for a reasonable jury to find for the nonmoving party. There are two main contexts:

• Pre-verdict: Motion made before the case goes to the jury.
• Post-verdict: Renewal after the jury verdict.

The movant must show that, viewing evidence in the nonmovant’s favor, no reasonable jury could decide otherwise. JMOL is stringent, reflecting the right to a jury trial, and is only granted where the evidence is unequivocally one-sided.

Statement of Material Facts

In some courts, like New York’s Commercial Division (22 NYCRR § 202.8-g), summary judgment motions must include a statement of material facts. This document:

• Lists each fact the moving party asserts is undisputed, with specific citation to admissible evidence.
• The opposing party must respond, indicating agreement or dispute, with supporting evidence.

Uncontroverted facts may be deemed admitted. Failure to comply can result in denial of the motion. This statement helps streamline the process and focus the court on actual disputes.

Material Fact

A material fact is a fact that could affect the outcome of a case under the governing law. Only disputes over material facts will preclude summary judgment; irrelevant or minor details do not count. The identification of material facts is based on the elements of the claim or defense at issue. For example, whether a contract was formed or breached may be a material fact in a contract case.

Genuine Issue

A genuine issue exists when the evidence is such that a reasonable jury could return a verdict for the nonmoving party. As articulated in Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986), it requires more than a minimal amount of evidence. If the record contains conflicting evidence on a material issue, summary judgment must be denied.

Prima Facie Case

A prima facie case is the establishment of a legally sufficient claim, supported by evidence that, if uncontradicted, entitles the party to relief. In dispositive motions, the moving party must make a prima facie showing of each claim element with admissible evidence. If not, the motion fails, regardless of the opponent’s evidence.

Burden of Proof

The burden of proof in dispositive motions is twofold:

1. The moving party must first show entitlement to judgment as a matter of law, with admissible evidence.
2. If successful, the burden shifts to the opposing party to present evidence of a genuine issue of material fact.

Conclusory assertions or unsworn statements are insufficient. The allocation of the burden ensures summary disposition only where the record is clear.

Procedural Compliance

Procedural compliance means adhering to all rules governing dispositive motions—timing, form, content, and supporting documents. For example, CPLR 3212(a) mandates a 120-day deadline for summary judgment after the note of issue in New York. Substantial noncompliance, such as missing deadlines or required affidavits, is generally fatal to the motion.

Dispositive Motions

Dispositive motions seek to resolve claims or defenses without trial, including motions for summary judgment, default judgment, and JMOL. These require strict evidentiary and procedural support. Dispositive motions help narrow trial issues, dismiss unmeritorious claims, and streamline litigation.

CPLR 3215: Default Judgment

CPLR 3215 details the process for obtaining default judgments in New York state courts. For sum certain claims, the clerk can enter judgment upon application within one year of default. For other claims, the court determines liability and conducts an inquest to fix damages. Mechanisms exist for vacating default judgments upon showing a reasonable excuse and a meritorious defense.

CPLR 3212: Summary Judgment

CPLR 3212 governs summary judgment in New York civil actions. The movant must show no triable issue of material fact and entitlement to judgment as a matter of law, supported by affidavits and other admissible evidence. The nonmovant must respond with evidence creating a triable issue. The court may grant full or partial summary judgment.

FRCP 56: Summary Judgment

FRCP 56 provides the federal standard for summary judgment. The rule requires the movant to show no genuine dispute as to any material fact and entitlement to judgment as a matter of law. The court views the evidence in the nonmovant’s favor and draws all reasonable inferences for them.

FRCP 50: Judgment as a Matter of Law

FRCP 50 governs judgment as a matter of law in federal court. A party may move for JMOL before or after a jury verdict if the evidence, viewed favorably to the nonmovant, is insufficient to support a reasonable jury finding. The rule ensures only claims supported by sufficient evidence reach a jury.

22 NYCRR § 202.8-g: Statement of Material Facts

This New York rule requires parties moving for summary judgment in the Commercial Division to submit a statement of material facts, each supported by admissible evidence. The opposing party must respond point-by-point. Courts may deem uncontroverted facts admitted, and noncompliance may result in denial of the motion.

Inquest

An inquest is a hearing to determine damages after liability has been established, often following a default. The court reviews evidence and may take testimony to assess actual damages. The inquest safeguards against windfalls and ensures judgments reflect actual losses.

Sum Certain

A sum certain is a specific, readily calculable monetary amount claimed, such as a fixed debt. For default judgment, if the claim is for a sum certain, the clerk can enter judgment. Claims for unliquidated damages require court assessment.

Affidavit of Service

An affidavit of service is a sworn statement documenting the date, time, place, and manner of serving legal papers. It is essential for proving proper notice and forms the basis for obtaining default judgment if the defendant fails to respond.

References:

• New York Civil Practice Law and Rules (CPLR) 3212, 3215
• Federal Rules of Civil Procedure 50, 56
• Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986)
• 22 NYCRR § 202.8-g

For further guidance on dispositive motions and criteria for judgment, consult a legal professional or court rules specific to your jurisdiction.