Sifuentes v. Platforms

Background

While Meta Platforms, Inc.’s motion to dismiss was pending, David Angel Sifuentes attempted to file three summary-judgment motions. He first included a “cross-motion for summary judgment and opposition to defendant’s motion to dismiss” with his opposition to the motion to dismiss. He then filed a separate summary-judgment motion and an amended summary-judgment motion.

Court’s reasoning

The court held that any summary-judgment motion was premature because Meta’s motion to dismiss remained pending, the pleadings had not been settled, and no fact discovery had occurred. Summary judgment is a procedure for deciding a claim based on the evidence when there is no genuine dispute about a material fact; the court concluded that this case was not ready for that procedure.

The court also noted that Sifuentes’s three attempts did not comply with Section G of Judge Tigar’s Civil Standing Order. That provision states that, absent good cause, the court will consider only one summary-judgment motion per party.

Ruling

Judge Jon S. Tigar denied the summary-judgment motions. The order states that Sifuentes may not refile such a motion at least unless and until Meta answers the complaint. The court terminated Meta’s motion for an extension of time to respond to the summary-judgment motion as moot, meaning that the request no longer required a ruling.

Scope of the ruling

The opinion addresses the timing and filing of the summary-judgment motions. It does not decide the merits of the claims described in the complaint or the pending motion to dismiss.