Connecticut Federal Court Denies WWE’s Motion for Summary Judgement Over Lengthy Briefs
A Connecticut Federal Judge has denied World Wresting Entertainment, Inc.’s motion for summary judgment regarding two former wrestlers’ claims that the long-term injuries associated with repeated head traumas were hidden from them, as both sides submitted briefs that were too long.
As background, former WWE wrestlers, Evan Singleton and Vito LoGrasso sued the WWE in January 2015 for the WWE’s alleged concealment of the long-term health risks associated with repeated head injuries, and further, mislead wrestlers into performing while injured — worsening their injuries.
In March 2016, three other former wrestlers had their cases dismissed, as they had not wrestled after the WWE allegedly learned about the long-term degenerative neurological diseases associated with multiple concussions in 2005.
Singleton’s and LoGrasso’s fraudulent omission claim was allowed to proceeds because they wrestled after 2005.
The WWE then moved for summary judgment on Singleton’s and LoGrasso’s claims. However, the motion was denied, as both parties Local Rule 56(a) statements — required with summary judgment motions in order to present the material, undisputed, facts — were excessive in length.
U.S. District Judge Vanessa L. Bryant’s order stated, “[i]nstead of submitting concise statements of each material fact…the parties have buried the court in extraneous information, a substantial portion of which is argument and not fact.” The order went on to state that the parties frustrated the purposes of Rule 56(a) statements by submitting such “unnecessarily voluminous Rule56(a) statements.”
The Federal Rules of Civil Procedure require parties submitting motions for summary judgment to attach a Rule 56(a) statement disclosing the facts the party claims to be undisputed. Then, the opposing party files a Rule 56(a) statement in opposition, which admits or denies the plaintiff’s contentions, and separately lists disputed facts. Thus, the 60-page and 125-page statements filed the parties here failed to conserve court resources and time, instead requiring the court to search for the facts itself.
The judge denied the motion without prejudice. Her order required that the WWE file a new Rule 56(a) statement — which must be less than 30 pages, and ordered the wrestlers to respond within 14 days, listing its responses to any facts alleged by the WWE, including a 30-page disputed issues section.
Bryant’s denial of the WWE’s motion illuminates the importance of following the guidelines set forth in the Federal Rule of Civil Procedure, as failing to submit a clear and concise statement in accordance with the rule’s requirements may result in dismissal of a party’s motion.