On March 2, 2026, the Dallas County District Courts issued a new General Order governing summary judgment practice. The General Order requires that all motions for summary judgment be filed at least 90 days before the next trial setting. Motions filed within 90 days of trial will be automatically denied unless the movant first receives leave of court. This General Order applies to all motions for summary judgment filed after March 2, 2026.

The General Order comes after the Texas Legislature recently enacted legislation requiring trial courts to issue written rulings on summary judgment motions within 90 days of the hearing or submission docket. Between the recent changes in the law and now this General Order, Texas courts—particularly in Dallas County—are taking control of summary judgment practice.

Below are several practical considerations for litigants and their counsel.

The Deadline Overrides Scheduling Orders and Agreements

By its own terms, the General Order supersedes scheduling orders and Rule 11 agreements. As a result, parties cannot modify the summary judgment deadline through agreement alone. Any motion filed inside the 90-day window requires leave of court.

Discovery Deadlines May Create Strategic Challenges

When drafting scheduling orders, litigants may want to consider placing the discovery deadline further from the trial setting than they might typically do. For example, in some cases, the General Order’s new timing requirement may require a party to file a motion for summary judgment while discovery is still ongoing. That situation could allow the nonmovant to argue that summary judgment is premature because discovery has not yet closed. As a result, litigants may want to consider seeking the amendment of current scheduling orders.

Uncertainty in Certain Courts

Based on the version of the General Order uploaded on the county’s website, the 101st District Court may not be adopting this rule, as Judge Staci Williams does not appear to have signed the General Order. Litigants with matters pending in the 101st District Court may want to seek clarification early in the case regarding whether the General Order will apply.

What This Means for Litigants

The new rule introduces a more rigid framework for summary judgment practice in the Dallas County District Courts. Litigants and their counsel should carefully review scheduling orders and tailor their litigation strategy accordingly to account for the earlier filing deadline.

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