For years, navigating a summary judgment motion in Texas courts could feel like throwing a document into a black hole. Under the old system, an attorney could file a motion, and if they failed to actively set a hearing, that motion would just float in the legal ether indefinitely. The burden was entirely on the moving party to force the issue, and responses weren't due until seven days before the hearing whenever that happened to be.
As of March 1, 2026, those days are officially over. The Texas judicial system has overhauled the summary judgment process under the Texas Rules of Civil Procedure (TRCP) Rule 166a, implementing strict new deadlines, mandatory court actions, and specific formatting requirements.
Here is exactly what you need to know about the new summary judgment "shot clock."
The New Summary Judgment "Shot Clock"
The biggest shift in the March 2026 update is the transition to a rigid timeline that forces both attorneys and judges to act promptly. The timeline is no longer anchored vaguely to whenever a hearing is set; it is now anchored to the exact date the motion is filed.
- 21-Day Response Deadline: If you are served with a summary judgment motion, you now have exactly 21 days from the date of filing to get your response on the record. You can no longer wait around for a hearing date to be scheduled before putting your defense together.
- Mandatory Hearing Window (35–60 Days): Judges can no longer ignore these motions. The court is now required to set a hearing (either an oral hearing or a hearing on submission in chambers) within 35 to 60 days of the motion being filed.
- 90-Day Ruling Deadline: After the hearing concludes, the judge has 90 days to issue a written ruling.
While the legal system still relies on judges to manage their own dockets—meaning a reminder motion might still be necessary if a judge misses that 90-day mark—the rules now explicitly mandate action, preventing cases from languishing for months on end.
Strict Titling and Hearing Requests
The new rules also crack down on procedural ambiguity. Previously, attorneys might file a generic "Motion for Summary Judgment," leaving the court and opposing counsel to read through the document to figure out exactly what legal standard was being argued.
Now, your motion must explicitly state its nature in the title. You must designate it as one of the following:
- Traditional Motion for Summary Judgment
- No-Evidence Motion for Summary Judgment
- Combined Motion for Summary Judgment
Additionally, the cover of your motion must now explicitly include a request for a hearing. Whether your specific court coordinator prefers you to call for available dates beforehand or wait for the court to assign one based on the new statutory timeline, the request itself must be documented upfront.
The Codified Right to Reply
Under the old rules, filing a reply to an opposing party's response was technically permissible, but it was largely governed by local court rules rather than the main TRCP. The March 2026 updates have formalized this right across the board.
If you are the moving party and the opposition files a response, you now have an explicit, statutory right to file a reply within 7 days after their response is filed.
While the rules allow you to have the last word in this formalized sequence, attorneys should use common sense before engaging in endless back-and-forth filings. While you can technically file "sur-replies" (a reply to their reply), doing so often irritates the court. Take advantage of your codified 7-day reply window to shut down new arguments, but know when to stop writing and let the judge make a decision.
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