Master the art of crafting a winning statement of undisputed material facts for summary judgment. Learn how to present facts clearly and persuasively to strengthen your case.
A well-drafted Statement of Undisputed Material Facts (SUF) is a cornerstone of a successful motion for summary judgment. This statement is where you clearly outline the facts of the case that are not in dispute, setting the stage for the court to rule in your favor without the need for a trial. A concise and persuasive SUF can significantly increase your chances of success by making it clear that no genuine issue of material fact exists.
In this article, Legal Husk provides guidance on how to craft a compelling Statement of Undisputed Material Facts that aligns with your legal arguments and strengthens your motion for summary judgment.
✅ The Statement of Undisputed Material Facts serves as the factual foundation for your summary judgment motion. It outlines the key facts that both parties agree upon and that are essential to the resolution of the case.
Clarifies the Legal Standard: The SUF helps the court determine whether the legal standard for summary judgment has been met—specifically, whether there are genuine disputes over material facts that would require trial.
Simplifies the Judge’s Job: By presenting the facts in a clear, organized manner, you make it easier for the judge to assess whether summary judgment is appropriate.
Sets the Stage for Legal Argument: The SUF frames your legal arguments by establishing the facts that support your claim, making it easier to show that the law favors your position.
🎯 Strategic Tip: Always ensure that your undisputed facts are directly relevant to the key legal issues in the case. This will allow you to connect the facts seamlessly with your legal arguments.
✅ The material facts are those facts that are crucial to the outcome of the case. When crafting your SUF, focus on presenting only those facts that are directly relevant to the legal issues at hand.
Essential Facts: These are facts that would affect the outcome of the case. For example, in a breach of contract case, facts about the existence of the contract, the performance of the parties, and the alleged breach are material.
Undisputed Facts: These are facts that both parties agree upon. It’s critical to distinguish between facts that are actually undisputed and those that might appear undisputed at first glance but are still subject to dispute.
Example: If both parties agree that the contract was signed on a specific date, that fact should be included in the SUF, but if there is a dispute over the terms of the contract, that should not be included as an undisputed fact.
🎯 Strategic Tip: Avoid overloading the SUF with unnecessary details. Stick to the key facts that drive the outcome of the case and support your legal arguments.
✅ A clear and logical structure is essential for making your Statement of Undisputed Material Facts easy for the court to follow. Present the facts in a sequence that mirrors the progression of the case.
Chronological Order: Present the facts in the order in which they occurred. This is especially important in cases where timelines are a crucial aspect of the dispute.
Example: "On January 5, 2022, Defendant agreed to deliver goods to Plaintiff. On January 10, 2022, Defendant shipped the goods, and Plaintiff received them on January 12, 2022."
Group Facts by Issue: If the case involves multiple issues, group related facts together to create a logical flow. For instance, in a contract dispute, you might have sections on contract formation, performance, and breach.
Example: "Section A: Contract Formation – On January 5, 2022, Defendant agreed to deliver goods; On January 6, 2022, Plaintiff confirmed acceptance."
🎯 Strategic Tip: The goal is to make the SUF as reader-friendly as possible. Organize facts in a way that leads the court to your legal conclusion.
✅ The language in your Statement of Undisputed Material Facts should be clear, precise, and free from unnecessary legal jargon. The goal is to make it as easy as possible for the judge to understand the facts.
Be Specific: Avoid vague or generalized statements. Provide clear and specific facts that are directly relevant to the issues at hand.
Example: Instead of saying, "Defendant did not deliver goods on time," say, "Defendant failed to deliver goods by the agreed-upon delivery date of January 10, 2022."
Avoid Legal Arguments: The SUF is not the place to argue the law or interpret the facts. Stick to presenting the facts themselves and save legal analysis for the argument section of the motion.
Use Simple Language: While the memorandum may be filled with legal arguments, the SUF should be straightforward and factual. Avoid unnecessary complexity or wordiness.
🎯 Strategic Tip: Be direct and factual in the SUF. The more straightforward the presentation of facts, the easier it will be for the judge to make a ruling.
✅ For each fact presented in your SUF, cross-reference the evidence that supports it. This will help you prove that the fact is truly undisputed and that it is backed by concrete evidence.
Cite Affidavits, Depositions, and Documents: Each fact should be supported by a reference to evidence, such as an affidavit, a deposition transcript, or a document. Include citations to the page numbers of the evidence when appropriate.
Example: "Plaintiff ordered 100 units from Defendant on January 5, 2022 (Exhibit A, Affidavit of Jane Doe, ¶ 4)."
Be Precise: When citing evidence, be as specific as possible. For example, if you’re citing a deposition, reference the relevant page and line numbers to make it easy for the judge to verify the fact.
🎯 Strategic Tip: Link each undisputed fact directly to the supporting evidence to strengthen your case and minimize the chance of disputes over the facts.
✅ While your goal is to present only undisputed facts, it’s helpful to anticipate any potential disputes and clarify them preemptively in your SUF. Address any points where there may be ambiguity, or where the opposing party may later claim a factual dispute.
Clarify Ambiguous Facts: If there’s any possibility that a fact could be disputed, address it in a way that minimizes the chance of confusion.
Example: "Plaintiff and Defendant agree that the contract was signed on January 5, 2022; however, Defendant argues that the delivery date was not clearly stated in the contract. The agreed delivery date, based on the shipping agreement attached as Exhibit B, was January 10, 2022."
Highlight Consistency: If both parties have provided evidence for the same fact, explain the consistency of the evidence, and point out any weaknesses in the opposing party’s evidence.
🎯 Strategic Tip: Be proactive about addressing potential disputes. Clarifying facts early can prevent the opposing party from later creating ambiguity around them.
Crafting a winning Statement of Undisputed Material Facts is a crucial step in successfully obtaining summary judgment. By focusing on clear, material facts, structuring the SUF logically, and supporting each fact with evidence, you can create a compelling argument for why the case should be resolved without trial.
At Legal Husk, we assist litigators in drafting persuasive Statements of Undisputed Material Facts that are concise, well-supported, and legally sound, ensuring your motion for summary judgment stands the best chance of success.
📌 Need expert help with drafting your Statement of Undisputed Material Facts?
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