A free online tool by Varghese Summersett is now available to help Texas attorneys and litigants navigate the most significant overhaul of summary judgment procedure in state history. MSJCalculator.com automatically computes every critical deadline under the newly amended Texas Rule of Civil Procedure 166a, which took effect March 1, 2026, and fundamentally restructured how summary judgment motions move through Texas state courts.
The Rule Change
Effective March 1, 2026, the Texas Supreme Court finalized amendments to TRCP Rule 166a (Misc. Docket No. 26-9012), implementing mandates from Senate Bill 293 and House Bill 16. The changes replace a decades-old, hearing-anchored deadline system with a forward-looking, filing-anchored model — and for the first time in Texas civil procedure history, impose binding deadlines on trial courts themselves.
Under the old rule, briefing deadlines floated based on when a hearing was scheduled. If no hearing was ever set, there was effectively no deadline at all, and motions could sit unresolved for months or years. The new rule anchors every deadline to the date the motion is filed, creates mandatory court action windows, and backs compliance with quarterly reporting to the Office of Court Administration and an annual report submitted to the Governor, Lieutenant Governor, and Speaker of the House.
What the Calculator Does
MSJCalculator.com takes the motion filing date as its only required input and instantly generates a complete deadline schedule:
- Day 21 — Nonmovant's response deadline
- Day 28 — Movant's reply deadline (7 days after response is filed)
- Day 35 — Earliest date the court may set a hearing or submission
- Day 60 — Standard deadline for the court to set a hearing or submission
- Day 90 — Extended court setting deadline (good cause or movant agreement required)
- 90 days post-hearing — Mandatory written ruling deadline
The calculator applies Texas Rule 4 to automatically roll deadlines forward when they fall on weekends or state holidays, includes a Dallas County local rule toggle for the 90-day pre-trial filing restriction, allows users to indicate whether they are the movant or nonmovant to highlight their key deadline, and generates a printable deadline schedule. The tool also provides embeddable code for attorneys or court websites who want to add the calculator to their own pages.
Why It Matters for Texas Litigants
The practical stakes of missing a deadline under the new rule are significant — particularly in personal injury cases where summary judgment is often a dispositive moment in the litigation. Benson Varghese, a Texas personal injury lawyer, put it directly: "Every litigator in Texas needs to rethink their summary judgment strategy from the ground up — plaintiff or defendant. The old habits are gone. The filing date is now the starting gun, and attorneys who don't adjust quickly are going to find themselves behind in ways that are very hard to recover from." Varghese authored a detailed practitioner's guide to the rule changes, available at VersusTexas.com.
The calculator is free, requires no registration, and is available at MSJCalculator.com.
The calculator is for informational purposes only and does not constitute legal advice. All deadlines must be independently verified with qualified counsel.
###
Media Contact
Melody McDonald
[email protected]
(817) 203-2220
300 Throckmorton Street Suite 700 Fort Worth TX 76102
