California summary judgment
MSJ Deadlines 2026: California Summary Judgment Timing
MSJ deadlines 2026 use California’s current summary judgment schedule for moving papers, opposition, reply, service, and the relationship between the hearing and trial.
This California summary judgment deadlines 2026 guide reads the current filing periods and moving-paper service adjustments from verified rule data. Always compare that statewide baseline with the assigned court’s calendar, local rules, and orders.
MSJ Deadlines 2026 at a Glance
The current MSJ schedule under CCP § 437c(a)(2) requires moving papers at least 81 calendar days before the hearing. Opposition is due at least 20 calendar days before the hearing under CCP § 437c(b)(2), and reply is due at least 11 calendar days before the hearing under CCP § 437c(b)(4).
| Schedule | MSJ moving papers | MSJ opposition and reply |
|---|---|---|
| Pre-2025 MSJ schedule | 75 calendar days | 14 and 5 calendar days |
| Current MSJ schedule | 81 calendar days | 20 and 11 calendar days |
Use the MSJ deadlines 2026 framework as a cross-check, not as a substitute for the assigned court’s current procedures.
AB 2049 Deadlines Replaced the Old Schedule
AB 2049 changed the statutory timing effective 2025-01-01. The familiar 75/14/5 shorthand describes the pre-2025 schedule, not the current periods. A checklist, form, or article that still uses those figures should not be used to calculate a current hearing without checking the amended statute.
The AB 2049 deadlines changed all three MSJ briefing intervals. Updating only the MSJ notice period while leaving the former opposition or reply period in place produces a mixed and incorrect schedule. Use one effective-date version of the statute throughout the MSJ schedule.
Keep MSJ deadlines 2026 on one coordinated timeline. Record the statute’s effective version, the selected hearing, and the trial date before approving the filing calendar; then calculate notice, opposition, and reply from the same verified hearing instead of mixing dates from different sources.
The 81-Day Moving-Paper Period
For the 2026 MSJ filing deadlines, start with the proposed hearing and count 81 calendar days backward for filing and service of the moving papers. Calendar days include weekends and judicial holidays within the interval, but a weekend or holiday can still affect the final landing date. Exclude the hearing date and apply the governing backward-landing rule.
For an MSJ, the notice period is only one constraint on hearing selection. The court must have an available slot, local procedures may require a reservation before filing, and trial proximity can make a seemingly available date unusable. Build the MSJ schedule from a confirmed hearing rather than an assumed date.
The 20-Day Opposition and 11-Day Reply Periods
MSJ opposition is counted 20 calendar days backward from the hearing. MSJ reply is counted 11 calendar days backward from that same hearing. Both MSJ calculations start from the hearing, not the moving-paper date or the other briefing deadline.
The MSJ statute also governs prompt delivery of opposition and reply. Review the current text of Code of Civil Procedure section 437c, the electronic filing rules, and any standing order for the department. The moving-paper service extensions described below do not extend opposition or reply periods.
MSJ Service Extensions in 2026
The following MSJ service adjustments apply to the moving papers. Each row keeps the configured number and unit because a calendar-day adjustment behaves differently from a court-day adjustment near weekends and judicial holidays. Personal service has its own configured zero value rather than an assumed extension.
| Service method | Adjustment | Authority |
|---|---|---|
| Personal service | 0 calendar days | No separate extension citation |
| Mail within California | 5 calendar days | CCP § 437c(a)(2) |
| Mail elsewhere in the United States | 10 calendar days | CCP § 437c(a)(2) |
| Mail outside the United States | 20 calendar days | CCP § 437c(a)(2) |
| Express delivery | 2 court days | CCP § 437c(a)(2) |
| Electronic service | 2 court days | CCP § 1010.6(a)(3)(B) |
Apply the selected row to MSJ moving papers only. Do not add these extensions to opposition or reply. Express delivery and electronic service use the unit shown in the table; check the result against the actual MSJ service facts and the statute in effect.
The Hearing Must Usually Precede Trial by 30 Days
CCP § 437c(a)(3) generally requires an MSJ hearing to occur at least 30 days before trial unless the court orders otherwise. This is a hearing constraint, not another filing extension. Work backward from the trial date when screening possible dates, then use the selected hearing to calculate the current briefing schedule. The AB 2049 deadlines do not replace this separate trial-gap constraint.
A continuance can change the MSJ trial-gap analysis. If trial moves, confirm whether the MSJ hearing or briefing dates also moved; if the hearing moves, recalculate all three filing dates and the service adjustment. Never assume a clerk’s reservation automatically updates a prior order.
Worked California Summary Judgment Deadlines 2026 Example
Assume the court has confirmed an MSJ hearing on 2026-12-04 that satisfies the trial-date gap. Count 81 calendar days backward to the base moving-paper date, then apply the rule-derived electronic-service adjustment of 2 court days under CCP § 1010.6(a)(3)(B). The resulting final filing-and-service date is 2026-09-10.
Return to the same hearing and independently count 20 calendar days for opposition, with the landing rule producing 2026-11-13. Count 11 calendar days for reply, producing 2026-11-23. The moving-paper electronic-service adjustment is not added to either later filing.
- MSJ hearing
- 2026-12-04
- Moving papers
- Electronic-service final: 2026-09-10
- Opposition
- 2026-11-13
- Reply
- 2026-11-23
To verify the 2026 MSJ filing deadlines, inspect every landing date for a weekend or judicial holiday and review delivery, e-filing, courtesy-copy, and reservation rules. The California MSJ deadline calculator shows each configured count and skipped or adjusted date so you can compare the output with your own calendar.
An MSJ Deadlines 2026 Verification Checklist
- Confirm the current statute applies and discard pre-2025 timing shorthand.
- Verify the MSJ hearing date, reservation, and required separation from trial.
- Count moving papers, opposition, and reply separately from the hearing.
- Apply the service adjustment only to moving papers.
- Check landing dates, filing hours, local rules, and standing orders.
- Preserve filed copies, proofs of service, and electronic receipts.
- Recalculate the MSJ schedule if the hearing or trial changes.
California summary judgment deadlines 2026 govern high-consequence papers and a detailed evidentiary record. This guide explains the statewide timing framework; official court resources and qualified counsel should resolve case-specific questions.
Quick Answers
Frequently Asked Questions
What Did AB 2049 Change for California MSJ Deadlines?
Effective Jan 1, 2025, AB 2049 changed the statutory timing from 75/14/5 days to 81 calendar days for notice under CCP § 437c(a)(2), 20 calendar days for opposition under CCP § 437c(b)(2), and 11 calendar days for reply under CCP § 437c(b)(4). Those are the current configured periods for a motion for summary judgment.
Are the 81, 20, and 11-Day Periods Court Days?
No. The periods are 81 calendar days for notice, 20 calendar days for opposition, and 11 calendar days for reply. A weekend or judicial holiday may still affect the final landing date under the applicable rule.
Do Service Extensions Apply to Every MSJ Filing?
The current rule data lists these moving-paper service adjustments: personal service: 0 calendar days; mail within California: 5 calendar days under CCP § 437c(a)(2); mail elsewhere in the United States: 10 calendar days under CCP § 437c(a)(2); international mail: 20 calendar days under CCP § 437c(a)(2); express delivery: 2 court days under CCP § 437c(a)(2); electronic service: 2 court days under CCP § 1010.6(a)(3)(B). They apply to notice and do not extend the opposition or reply periods in the calculator’s schedule.
How Much Time Must Separate the MSJ Hearing and Trial?
An MSJ hearing generally must occur at least 30 days before trial unless the court orders otherwise. The MSJ deadlines 2026 trial gap can therefore constrain which hearing dates are available.