Background
Tarelle D. Craft and Damon Nivens sued State Farm Mutual Automobile Insurance Company in Louisiana’s 19th Judicial District Court. State Farm moved for summary judgment and, in its reply supporting that motion, objected to evidence submitted by the plaintiffs.
On May 28, 2026, the trial court denied State Farm’s summary-judgment motion without ruling on the evidentiary objection. State Farm sought supervisory review from the Louisiana Court of Appeal, First Circuit.
The Court’s Holding
The First Circuit granted State Farm’s writ application and vacated the order denying summary judgment. The court explained that Louisiana Code of Civil Procedure article 966(D)(2) requires a trial court to state specifically, on the record or in writing, whether it sustains or overrules objections raised concerning summary-judgment evidence.
Because the trial court did not rule on State Farm’s objection, the appellate court remanded the matter for compliance with article 966(D)(2). It ordered the trial court to determine the evidentiary issues and then rule again on State Farm’s summary-judgment motion pursuant to article 966(C)(4). The First Circuit did not decide whether State Farm was entitled to summary judgment on the merits.
Key Takeaways
- A Louisiana trial court must expressly sustain or overrule evidentiary objections raised in summary-judgment proceedings.
- A summary-judgment ruling may be vacated when the court fails to resolve an objection to evidence on which the motion depends.
- The writ disposition required reconsideration after the evidentiary issues are decided; it did not award summary judgment to State Farm.
Why It Matters
The order underscores that Louisiana’s summary-judgment procedure requires an explicit evidentiary record. Trial courts cannot leave objections unresolved before deciding whether the submitted materials establish or defeat the absence of a genuine issue of material fact.
For practitioners, the decision highlights the importance of preserving objections to summary-judgment evidence and confirming that the trial court rules on each objection before reaching the motion’s merits.