Rule 56.1.Summary judgment -- required statement of material facts
Group VII: Judgment · Last amended March 1, 2017 · Last verified July 14, 2026
Full Text of Rule 56.1
Amendment History
Added February 2, 2017, effective March 1, 2017.
Plain-English Summary
Rule 56.1 is a local companion to Rule 56, built to make summary judgment motions easier for a judge to evaluate. A party moving for summary judgment cannot just cite evidence scattered through a brief; it must attach a separate, short statement listing the specific material facts it contends are not disputed. The idea is to give the court, at a glance, the factual skeleton the movant says entitles it to judgment.
A party opposing the motion faces the mirror-image requirement: its own separate statement identifying which material facts it says are in dispute. Both statements must include pinpoint citations to the exact portions of the record that support each fact, rather than a general reference to an exhibit or deposition. Read together with Rule 56(c), which already requires factual assertions to be tied to particular record materials, Rule 56.1 turns that requirement into a structured, itemized format that keeps summary judgment practice organized and makes it far easier for a judge to see exactly where the parties agree and where they do not.
Frequently Asked Questions
Do I need a Rule 56.1 statement every time I move for summary judgment?
Yes. Any motion for summary judgment under Rule 56 must come with a separate, short statement of the material facts the movant contends are not disputed.
What has to be in a Rule 56.1 statement?
A concise list of the material facts you say are (or are not) in dispute, each backed by a pinpoint citation to the specific part of the record that supports it.
Do I need a separate statement when I'm opposing summary judgment, not filing it?
Yes. The opposing party must also submit its own separate statement identifying the material facts it contends remain in dispute.
What does 'pinpoint citation' mean and why does it matter?
It means citing the exact page, paragraph, or line in the record that supports a fact, rather than pointing broadly at an entire deposition or exhibit. Pinpoint citations let the judge verify each factual assertion without having to search the whole record.
What happens if I skip the Rule 56.1 statement entirely?
The rule's requirements are mandatory for both sides on a summary judgment motion, and courts routinely rely on the statements to identify what is disputed, so omitting one undercuts your motion or opposition and invites the court to disregard unsupported factual claims.