D.C. summary judgment: numbered statements of fact, and a special rule for debt-collection cases
District of Columbia procedure · Last verified August 17, 2026
The District's Rule 56 follows the modern federal text, with two additions that matter in practice. Both sides must file a numbered statement of facts, and there is a provision for consumer debt collection cases that has no federal counterpart at all.
The filing window
Rule 56(b)(1) sets it:
Unless the court orders otherwise, a party may file a motion for summary judgment at any time until 30 days after the close of all discovery.
Thirty days after discovery closes — the same construction Vermont and West Virginia use. The scheduling order displaces it.
Rule 56 sets no response or reply deadline. Those come from Superior Court's general motions practice and from the order governing your case, so confirm them rather than assuming a figure from another jurisdiction.
Both sides file a numbered statement
Rule 56(b)(2) is the formatting requirement, and it binds movant and opponent alike.
The movant — Rule 56(b)(2)(A):
The movant must file a statement of the material facts that the movant contends are not genuinely disputed. Each material fact must be stated in a separate numbered paragraph.
The opponent — Rule 56(b)(2)(B):
A party opposing the motion must file a statement of the material facts that the opponent contends are genuinely disputed. The disputed material facts must be stated in separate numbered paragraphs that correspond to the extent possible with the numbering of the paragraphs in the movant's statement.
"Correspond to the extent possible with the numbering" is softer than the paragraph-by-paragraph reproduction Vermont demands, but it is doing the same job: the court has to be able to line your paragraph 7 up against the movant's paragraph 7. Where your dispute does not map onto a single numbered assertion, say so expressly rather than leaving the correspondence to be guessed at.
Unlike Maine and South Dakota, D.C.'s rule does not state that an uncontroverted fact is deemed admitted. The consequence provision is Rule 56(e), below, which gives the court a range of responses rather than an automatic admission.
Debt collection cases have an extra gate
Rule 56(a)(2) is the District-specific provision, and it is a precondition to judgment rather than a formatting rule:
In an action initiated by a debt collector to collect a consumer debt as defined in D.C. Code § 28-3814, the plaintiff must provide all documentation and information required by D.C. Code § 28-3814 prior to entry of summary judgment.
Two things follow. If you act for a debt buyer or collector, the documentation package is not something to be produced if challenged — the rule conditions entry of judgment on providing it. And if you are defending a collection suit, the absence of that documentation is a Rule 56 point in itself, independent of whether you can dispute the underlying debt.
Note the reach of the provision: it applies to an action "initiated by a debt collector to collect a consumer debt as defined in D.C. Code § 28-3814," so both the identity of the plaintiff and the character of the debt are defined by the statute, not by the rule.
The standard
Rule 56(a)(1) states it, and adds a direction to the judge:
A party may move for summary judgment, identifying each claim or defense—or the part of each claim or defense—on which summary judgment is sought. The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law. The court should state on the record the reasons for granting or denying the motion.
Supporting and disputing facts
Rule 56(c)(1) gives the two routes, in the familiar federal terms:
A party asserting that a fact cannot be or is genuinely disputed must support the assertion by: (A) citing to particular parts of materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the motion only), admissions, interrogatory answers, or other materials; or (B) showing that the materials cited do not establish the absence or presence of a genuine dispute, or that an adverse party cannot produce admissible evidence to support the fact.
Rule 56(c)(2) preserves the admissibility objection: "A party may object that the material cited to support or dispute a fact cannot be presented in a form that would be admissible in evidence."
Rule 56(c)(3) sets the court's reading obligation: "The court need consider only the cited materials, but it may consider other materials in the record." Cite what you need the judge to read; do not rely on the record speaking for itself.
Affidavits and declarations, under Rule 56(c)(4), must "be made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant or declarant is competent to testify on the matters stated."
When you cannot oppose yet
Rule 56(d):
If a nonmovant shows by affidavit or declaration that, for specified reasons, it cannot present facts essential to justify its opposition, the court may: (1) defer considering the motion or deny it; (2) allow time to obtain affidavits or declarations or to take discovery; or (3) issue any other appropriate order.
"Specified reasons" is the operative phrase — identify what you expect the discovery to produce and why you do not have it.
Failing to address a fact
Rule 56(e) supplies the consequence, and it is discretionary:
If a party fails to properly support an assertion of fact or fails to properly address another party's assertion of fact as required by Rule 56(c), the court may: (1) give an opportunity to properly support or address the fact; (2) consider the fact undisputed for purposes of the motion; (3) grant summary judgment if the motion and supporting materials—including the facts considered undisputed—show that the movant is entitled to it; or (4) issue any other appropriate order.
Judgment beyond the motion
Rule 56(f) permits the court to go further than either side asked, on notice:
After giving notice and a reasonable time to respond, the court may: (1) grant summary judgment for a nonmovant; (2) grant the motion on grounds not raised by a party; or (3) consider summary judgment on its own after identifying for the parties material facts that may not be genuinely in dispute.
Rule 56(g) covers the partial result, letting the court enter an order stating any material fact "including an item of damages or other relief" that is not genuinely in dispute and treating it as established.