Cross-motions for summary judgment are opposing motions filed by both parties on the same issues.

Default occurs when a defendant fails to plead or otherwise defend, permitting judgment without adjudication of the merits.

Dismissal with prejudice terminates a claim permanently, barring the plaintiff from refiling it.

A genuine dispute of material fact is a factual disagreement a reasonable jury could resolve either way on an issue that affects the outcome.

Judgment as a matter of law is entered during trial when no reasonable jury could find for the non-moving party.

A motion for judgment on the pleadings seeks resolution based solely on the pleadings after they are closed.

A motion for summary judgment asks the court to enter judgment without trial because no genuine dispute of material fact exists.

A motion to dismiss asks the court to dismiss claims without reaching the merits, most often for failure to state a claim on which relief can be granted.

A no-evidence motion asserts that the non-movant lacks evidence on an essential element, shifting the burden to produce it.

Partial summary judgment resolves specific claims, defenses, or issues without disposing of the entire case.

Rule 12(b) defenses are the threshold challenges a defendant may raise by motion before answering.

A Rule 12(b)(6) motion seeks dismissal on the ground that the complaint fails to state a claim on which relief can be granted.

The sham affidavit rule permits disregarding an affidavit that contradicts the affiant's prior sworn testimony without explanation.

A statement of undisputed material facts is the required itemized list of facts supporting a summary judgment motion.

The summary judgment record is the evidentiary material the court may consider in ruling on the motion.