Main Practice Contacts

Lynne Liberato
+1 713.547.2017


Nina Cortell
+1 214.651.5579


Karen S. Precella
+1 817.347.6620

Related Services




Summary Judgments

The skills necessary to pursue or defend against a summary judgment are the same skills as those necessary to handle an appeal. Cases are won or lost on written advocacy and technical proficiency. Those factors and the frequency with which summary judgments are appealed add up to extensive experience by Haynes and Boone's appellate lawyers in handling summary judgment proceedings.

Our lawyers also have developed the specialized knowledge and recognition that comes from authoring articles on summary judgment practice, particularly "Summary Judgments in Texas," which is often called the "bible" of summary judgment practice. Versions of this article have appeared in five law reviews since 1989, and it has been recognized as one of the nation's 10 most-cited articles by appellate courts.

Summary judgments are an integral aspect of pretrial proceedings. As a result, our appellate lawyers may handle them in due course during their partnership with trial counsel. Other times, we are hired for the particular purpose of pursuing or defeating a summary judgment. We have handled summary judgment proceedings in state and federal trial and appellate courts in commercial, personal injury, oil and gas, family and probate law cases with the following results:


  • Knocked out entire claims, resulting in a complete victory for our clients;
  • Simultaneously won summary judgment for our client and successfully defeated our opponent's cross motion for summary judgment;
  • Won partial summary judgment limiting our client's potential liability;
  • Won summary judgment on liability leaving damages and/or attorneys' fees the only issues to be tried;
  • Defeated summary judgments that would have limited our opponents' liability or eliminated our claims;
  • Obtained reversal on appeal of a summary judgment granted against our client and rendition of a judgment in the client's favor; and
  • Successfully defended summary judgments on appeal.