May 15, 2025 | JacobiJournal.com – Summary Judgment Motion: A California appellate court recently held that an insurance carrier could not revive a previously denied summary judgment motion by simply re-filing it without significant new evidence or legal developments. The decision underscores judicial expectations for diligence and finality in motion practice, particularly within workers’ compensation and insurance litigation.
Court Rejects Second Bite at the Apple
In the case, the insurance carrier initially sought summary judgment, arguing there was no triable issue of material fact regarding its liability in a complex coverage dispute. The trial court denied that motion. Later, the carrier attempted to reassert the same motion, citing no substantial change in law or facts. The court ruled that such renewed motions are improper without materially different circumstances.
The appellate court agreed. It stated that courts must discourage repetitive filings that waste judicial resources and delay proceedings. “A motion denied cannot be repackaged and re-presented in hopes of a different outcome,” the court noted.
Legal Standards and Implications
California law allows for renewed motions for summary judgment only if the party shows:
- New or different facts,
- A change in the law, or
- New circumstances that justify reconsideration.
In this instance, none of those criteria were met. The decision reinforces that parties cannot bypass procedural finality merely because they disagree with an earlier ruling.
Why This Matters
This ruling has broad implications for insurance defense teams and third-party administrators. It highlights the importance of making the strongest case possible in the initial motion, knowing that courts frown upon do-overs. Carriers must approach summary judgment strategically—gathering solid evidence and anticipating potential defenses—because a second chance is not guaranteed.
The decision also signals to plaintiffs’ counsel that courts will protect the integrity of the litigation process by rejecting duplicative tactics from insurers.
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