For more than a century in New York, summary judgment has offered an efficient way to resolve disputed matters presenting only questions of law (Merritt Hill Vineyards v. Windy Hgts. Vineyard, 61 NY2d 106, 112 [1984]). Any party may move for summary judgment in any action after issue has been joined.

Personal injury cases present a particularly fertile ground for such motions. When judgment as a matter of law should be granted is often not clearcut. Indeed, appellate courts reverse many orders resolving such motions.