In our March 5, 2026 Top Tip, we wrote about significant changes to summary judgment motion practice in Texas state courts. In short, Texas summary judgment practice has undergone a significant procedural overhaul, with a complete rewrite of Rule 166a effective March 1, 2026, in response to recent legislation. Most notably, response deadlines are now triggered by the filing of the motion—rather than the hearing date—giving nonmovants just 21 days to respond and submit evidence. The amendments also introduce more structured requirements for motion titles, evidence submission, proposed orders, and court scheduling, aligning Texas practice more closely with federal procedures. Overall, the changes place a premium on early preparation and strict calendar management to avoid missed deadlines and increased risk. 

But it is not just litigants affected by these new rules. Courts are also grappling with new, affirmative responsibilities they have with respect to setting motions for hearing or submission within defined timeframes, as well as giving notice to all parties. Additionally, courts must issue a…