Lakeland Premier Women’s Clinic v. Jackson: Strict Limits on Rule 56(f) Extensions and the Expert Affidavit Requirement in Mississippi Medical Malpractice Cases

Lakeland Premier Women’s Clinic v. Jackson: Strict Limits on Rule 56(f) Extensions and the Expert Affidavit Requirement in Mississippi Medical Malpractice Cases

I. Introduction

A. The Parties and the Dispute

The case Lakeland Premier Women’s Clinic, PLLC and Natasha N. Hardeman, M.D. v. Lakisha Jackson, decided by the Supreme Court of Mississippi on October 30, 2025, arises from an alleged medical malpractice incident following gynecologic surgery.

  • Plaintiff: Lakisha Jackson, a patient who underwent surgery and later developed a perforated small bowel and sepsis.
  • Defendants:
    • Lakeland Premier Women’s Clinic, PLLC (the clinic), and
    • Dr. Natasha N. Hardeman (the surgeon).
  • Other originally named defendant: Surgicare of Jackson, which obtained summary judgment in April 2024 and is not part of this appeal.

The plaintiff alleged that the laparoscopic bilateral tubal ligation and endometrial ablation performed on December 14, 2021, were negligently performed, resulting in a distal small-bowel perforation, sepsis, ICU admission, and subsequent corrective surgery by another physician.

B. Procedural Background

On April 13, 2023, Jackson filed a medical negligence complaint in the Hinds County Circuit Court. As required by Mississippi Code Section 11-1-58(1)(a), she attached a certificate of expert consultation, in which her attorney certified having consulted a qualified medical expert and concluded that there was a reasonable basis to commence the action.

On September 13, 2023, the clinic and Dr. Hardeman filed a motion for summary judgment under Mississippi Rule of Civil Procedure 56, supported by an expert affidavit from Dr. D. Kyle Ball, opining that there was no breach of the applicable standard of care.

Key procedural events followed:

  • February 6, 2024: Defendants noticed a hearing on the summary-judgment motion for March 26, 2024.
  • By that time: Jackson had filed no expert affidavit or substantive opposition.
  • March 25, 2024: Jackson filed a response, but:
    • It contained no expert affidavit, and
    • It consisted only of general assertions about deficiencies in records and a request for more time/discovery.
  • March 26, 2024 hearing: A hearing was held; there is no transcript in the record.
  • March 27, 2024 order: The circuit court:
    • Denied the motion for summary judgment, and
    • Reset a second hearing for April 29, 2024 (later held on May 1, 2024), effectively giving Jackson more time to obtain an expert affidavit.
  • April 16, 2024: Jackson filed an amended response including an expert affidavit from Dr. John P. Brennan.
  • May 1, 2024 hearing: The trial judge stated he had given Jackson’s counsel “30 days to respond … and get an affidavit” at the March 26 hearing and again denied summary judgment, now on the basis that Dr. Brennan’s affidavit allegedly conflicted with Dr. Ball’s.
  • Interlocutory appeal: The defendants petitioned for interlocutory appeal and a stay; the Supreme Court granted the petition on July 3, 2024.

C. Central Legal Issues

The Supreme Court addressed two interlocking questions:

  1. Whether, in a medical malpractice case, a plaintiff who fails to submit expert evidence by the time of the summary-judgment hearing can avoid summary judgment simply by filing a late response asking for more discovery.
  2. Whether a trial court may, sua sponte (on its own initiative) and without a proper showing under Rule 56(f), grant the plaintiff additional time to secure an expert affidavit and then rely on that late affidavit to deny summary judgment.

The case thus squarely concerns the interaction between:

  • The expert testimony requirement in medical malpractice cases;
  • The summary judgment framework under Rule 56(c) and 56(e); and
  • The continuance/extension mechanism under Rule 56(f).

II. Summary of the Supreme Court’s Opinion

The Supreme Court of Mississippi reversed the circuit court’s denial of summary judgment and rendered judgment in favor of Lakeland Premier and Dr. Hardeman.

A. Holding

  1. Expert testimony is indispensable at the summary-judgment stage in medical malpractice cases.
    Because Jackson did not submit any expert affidavit or testimony by the March 26, 2024 hearing, and her response consisted only of generalized assertions and a request for more discovery, she failed to establish a prima facie case. Under existing Mississippi precedent, this failure mandated summary judgment for the defendants.
  2. The circuit court abused its discretion under Rule 56(f).
    The trial court sua sponte granted Jackson an additional thirty days to obtain an expert affidavit without:
    • Any Rule 56(f) affidavit or equivalent evidentiary showing by Jackson,
    • Any specific facts explaining why essential facts could not then be presented, or
    • Any findings that Jackson had acted with diligence and in good faith.
    Under Vicksburg Healthcare, LLC v. Dees and related cases, this was an abuse of discretion.
  3. Subsequently obtained expert testimony cannot cure the earlier failure.
    Because summary judgment should have been granted as of the March 26 hearing (when defendants had an expert affidavit and plaintiff did not), the later-filed expert affidavit by Dr. Brennan could not salvage Jackson’s claim. The Court treated the denial of summary judgment at that point as error and rendered judgment for the defendants.

B. Disposition

  • The Court applied a de novo review to the denial of summary judgment.
  • It applied an abuse-of-discretion standard to the trial court’s Rule 56(f) extension.
  • It held that:
    • No genuine issue of material fact existed at the time of the March hearing, and
    • The circuit court abused its discretion in granting extra time under Rule 56(f).
  • The judgment of the circuit court was reversed, and summary judgment was rendered in favor of Lakeland Premier and Dr. Hardeman.

III. Analysis

A. Precedents and Authorities Cited

The Court’s reasoning is anchored in a line of Mississippi cases about:

  • The evidentiary burden on plaintiffs in medical malpractice cases;
  • The function and timing of summary judgment under Rule 56; and
  • The narrow circumstances in which a Rule 56(f) continuance is proper.

1. Vicksburg Healthcare, LLC v. Dees, 152 So. 3d 1171 (Miss. 2014)

Dees is the central precedent and is expressly applied to this case.

  • Facts in Dees:
    • Medical negligence action; plaintiff filed a certificate of expert consultation with the complaint.
    • Defendant moved for summary judgment, arguing plaintiff had designated no expert and presented no expert evidence.
    • Plaintiff responded by naming an expert but provided no affidavit or sworn testimony.
    • The trial court nonetheless denied summary judgment and sua sponte gave the plaintiff more time to obtain an affidavit.
  • Holding:
    • Because plaintiff failed to submit sworn expert testimony by the hearing, summary judgment was mandatory.
    • The trial court abused its discretion by granting extra time under Rule 56(f) absent any affidavit or showing of specific facts, diligence, or good faith.

In Lakeland Premier, the Court quotes and relies heavily on Dees for two intertwined propositions:

  1. Substantive rule: In medical malpractice cases, failure to produce expert testimony by the summary-judgment stage “generally requires a grant of summary judgment.”
  2. Procedural rule: A Rule 56(f) continuance requires:
    • Specific facts explaining why essential evidence cannot yet be produced,
    • An account of what steps have been taken to obtain that evidence, and
    • A basis to find that the nonmovant has been diligent and acted in good faith.
    Absent these showings, granting extra time is an abuse of discretion.

The Court treats the present case as materially indistinguishable from Dees, reinforcing and extending its holding.

2. Lindsey v. Butts, 382 So. 3d 1140 (Miss. 2024)

Lindsey v. Butts is cited for the broad proposition that when a medical malpractice plaintiff fails to provide expert testimony establishing a prima facie case, summary judgment is required.

The Court quotes Lindsey (itself quoting Claiborne County Hospital v. Truitt):

“When a plaintiff fails to provide expert testimony establishing a prima facie case of medical malpractice, a grant of summary judgment is required.”

This reinforces that the deficiency here – Jackson’s lack of any expert affidavit at the March hearing – is not a minor procedural flaw, but a substantive failure of proof that compels judgment for the defense.

3. Johnson v. Pace, 122 So. 3d 66 (Miss. 2013) and Palmer v. Biloxi Regional Medical Center, Inc., 564 So. 2d 1346 (Miss. 1990)

These cases establish that, in medical-malpractice summary-judgment practice, the burden of production shifts to the plaintiff once the defendant makes a properly supported motion.

  • Johnson v. Pace: The plaintiff bears the burden of production in response to a medical-malpractice summary-judgment motion.
  • Palmer: Early case framing the requirement that expert testimony is normally needed to establish breach and causation in medical negligence claims.

Lakeland Premier applies this framework: once defendants supported their motion with an expert affidavit (Dr. Ball), Jackson had to counter with expert evidence. She did not do so in time.

4. Crosthwait v. Southern Health Corp. of Houston, Inc., 94 So. 3d 1070 (Miss. 2012) and Kuiper v. Tarnabine, 20 So. 3d 658 (Miss. 2009)

These cases set out the elements of a medical-negligence claim and the necessity of expert proof.

To establish a prima facie case of medical malpractice in Mississippi, a plaintiff must show:

  1. The defendant’s duty to conform to a specific professional standard of care;
  2. A failure to conform (breach) of that standard; and
  3. Injury proximately caused by that breach, with proof of damages.

As reiterated in Lakeland Premier, “Expert testimony is essential to establish these elements, and without it, summary judgment generally must be granted.”

5. Norman v. Anderson Regional Medical Center, 262 So. 3d 520 (Miss. 2019) and Hubbard v. Wansley, 954 So. 2d 951 (Miss. 2007)

These cases address the inadequacy of bare allegations or generalized responses to summary-judgment motions in medical-malpractice cases.

  • Norman holds that a plaintiff’s failure to produce sworn expert testimony is fatal at the summary-judgment stage.
  • Hubbard similarly emphasizes that a plaintiff must go beyond the pleadings and provide expert evidence.

Lakeland Premier applies these decisions directly to Jackson’s March 25, 2024 response, which:

  • Contained only a “general assertion of deficiency in ‘the medical records provided,’”
  • Requested denial of summary judgment and more discovery, and
  • Was not supported by any affidavit or expert testimony.

Under Rule 56(e) and these cases, such a response is legally insufficient.

6. Owens v. Thomae, 759 So. 2d 1117 (Miss. 1999)

Owens supplies the core standard for granting additional time under Rule 56(f). As quoted in Dees and reiterated in Lakeland Premier:

  • The party seeking more time must present specific facts explaining why the motion cannot be opposed at that time.
  • The party must also show what actions have been taken to obtain the necessary information.
  • Any extension must be premised on a conclusion that the party has been diligent and has acted in good faith.

In Lakeland Premier, the Court finds:

  • No Rule 56(f) affidavit was filed by Jackson.
  • No record evidence shows any specific facts or steps taken to secure an expert.
  • The trial court made no findings on diligence or good faith.

On this record, granting thirty extra days was an abuse of discretion under Owens and Dees.

7. Thomas v. Bolivar County, 404 So. 3d 1136 (Miss. 2023); Williams v. City of Batesville, 313 So. 3d 479 (Miss. 2021); and Uniform Civil Rule of Circuit and County Court Practice 4.02

The timing of Jackson’s response is evaluated with reference to Uniform Civil Rule 4.02 and recent case law.

  • Rule 4.02 (paraphrased) provides a 10-day period relating to the filing of responses to motions.
  • Williams clarified that some Rule 4.02 timing requirements are not part of Rule 56’s summary-judgment procedure and exist for the benefit of the trial judge.
  • Thomas shows that, on appellate review, the Supreme Court still considers the extent to which a party flouted Rule 4.02’s timing requirements.

In Lakeland Premier, the Court notes that Jackson’s response was filed “well outside the ten days allotted by … Rule 4.02” and treats that delay as part of the context. Although not dispositive by itself, it reinforces the sense that Jackson was not diligent in preparing her case.

8. Other Authorities

  • Estate of Northrop v. Hutto, 9 So. 3d 381 (Miss. 2009), and Neely v. North Mississippi Medical Center, Inc., 996 So. 2d 726 (Miss. 2008): These cases supply general summary-judgment standards—view evidence in the light most favorable to the nonmovant; if no genuine issue of material fact exists, summary judgment is required.
  • Claiborne County Hospital v. Truitt, 335 So. 3d 562 (Miss. 2022): Reiterates that lack of expert testimony requires summary judgment in medical-malpractice cases; quoted in Lindsey and again in this opinion.
  • Mississippi Code § 11-1-58(1)(a): Requires a “certificate of expert consultation” at the pleading stage in medical-malpractice suits. The Court’s analysis implicitly confirms that this certificate is not a substitute for an expert affidavit at summary judgment.

B. The Court’s Legal Reasoning

1. Summary Judgment Standards and Burden-Shifting

The Court first recites the familiar summary-judgment framework under Mississippi Rule of Civil Procedure 56:

  • A defendant may move for summary judgment “at any time” (Rule 56(b)).
  • The motion must be served at least ten days before the hearing (Rule 56(c)).
  • The nonmovant may serve opposing affidavits up to the day before the hearing (Rule 56(c)).
  • When a motion is properly supported, the opposing party:
    • “may not rest upon the mere allegations or denials of his pleadings,” and
    • must “by affidavits or as otherwise provided … set forth specific facts showing that there is a genuine issue for trial” (Rule 56(e)).

Applied to medical-malpractice cases, once a defendant supports its motion with an expert affidavit showing no breach of the standard of care, the plaintiff must counter with expert testimony. Mere argument or unsworn allegations are insufficient.

Here:

  • The defendants filed a motion with an expert affidavit (Dr. Ball) stating no breach of the standard of care.
  • Jackson responded on March 25, 2024, without any expert affidavit and without calling any expert to testify at the March 26 hearing.
  • Her response contained only a generalized assertion about deficiencies in medical records and a request to continue discovery.

Under Rule 56(e) and the cited cases (Norman, Hubbard, etc.), such a response fails to “set forth specific facts showing that there is a genuine issue for trial.” As of the March hearing, therefore, no genuine issue of material fact existed, and summary judgment was required.

2. The Essential Role of Expert Testimony in Medical Malpractice

The Court reiterates that in virtually all medical-malpractice cases, expert testimony is “essential” to:

  • Articulate the applicable standard of care;
  • Show that the defendant deviated from that standard; and
  • Establish a causal link between that deviation and the plaintiff’s alleged injury.

Without such testimony, the plaintiff cannot establish a prima facie case. This principle is drawn from Crosthwait, Kuiper, Dees, Lindsey, and Truitt.

In this case:

  • Jackson did file a certificate of expert consultation with her complaint, as required by § 11-1-58(1)(a).
  • However, that certificate is an attorney’s certification—not sworn expert evidence. It merely confirms that an expert was consulted and found a reasonable basis for filing suit.
  • The certificate does not satisfy the requirement for expert testimony at the summary-judgment stage.
  • Jackson still had to produce an expert affidavit (or other sworn evidence) establishing:
    • The standard of care;
    • How defendants breached it; and
    • That the breach proximately caused her small-bowel perforation and resulting sepsis and damages.

She did not do so until after the trial court had already denied summary judgment and granted an extension.

3. Rule 56(f) and the Limits on Granting Additional Time

The heart of the opinion lies in the Court’s treatment of Rule 56(f).

Rule 56(f) allows a trial court, in its discretion, to:

  • Deny a summary-judgment motion, or
  • Order a continuance to permit discovery or evidence-gathering,

if the nonmovant shows, by affidavit, that they cannot yet present facts essential to oppose the motion.

But the Court stresses that this is not a routine, automatic safety valve; it is a narrow exception requiring:

  1. A specific evidentiary showing.
    • The nonmovant must present specific facts explaining why the essential evidence is not currently available.
    • Generic requests to “complete discovery” or claims that more information is needed are insufficient.
  2. An account of diligence.
    • The nonmovant must show what actions have already been taken to obtain the required evidence.
    • This includes efforts to retain experts, collect records, or otherwise develop proof.
  3. A finding of good faith and diligence by the trial court.
    • The trial court must be able to conclude that the nonmovant has been diligent and has acted in good faith.
    • Only then is it appropriate to grant additional time.

In Lakeland Premier:

  • Jackson provided no Rule 56(f) affidavit.
  • Her response contained no detailed explanation why she had no expert affidavit yet, despite a certificate of consultation on file and the passage of substantial time (approximately 194 days after the summary-judgment motion).
  • There is no indication in the record that she described steps taken to secure an expert opinion or any obstacles encountered.
  • The circuit court made no findings about diligence or good faith; the only statement we have is that it granted “30 days to respond … and get an affidavit.”

Under Dees and Owens, this falls far short of Rule 56(f)’s requirements. The Supreme Court therefore holds that granting the 30-day extension was an abuse of discretion.

4. Why Later-Filed Expert Proof Cannot Cure the Error

Jackson ultimately did file an expert affidavit (Dr. Brennan) on April 16, 2024, and the trial court later relied on that affidavit to deny summary judgment after the May 1 hearing.

However, because:

  • As of March 26, the defendants had met their summary-judgment burden (via Dr. Ball’s affidavit), and
  • Jackson had failed to produce any countervailing expert testimony or satisfy Rule 56(f),

the only legally permissible outcome at that time was the granting of summary judgment.

The Supreme Court essentially “rewinds the tape” to the moment of the March hearing and asks:

On that record, applying the correct legal standards, should summary judgment have been granted?

Its answer is yes. Therefore:

  • The trial court’s initial denial of summary judgment was error.
  • The later-filed expert affidavit and subsequent order denying summary judgment do not change the analysis, because the extension allowing that affidavit was itself an abuse of discretion.
  • The Supreme Court does not merely remand for further proceedings; it renders summary judgment for the defendants, closing the case.

C. Impact and Practical Implications

1. For Plaintiffs in Medical Malpractice Cases

This decision sends a clear message to plaintiffs’ counsel:

  • The certificate of expert consultation required by § 11-1-58 is not enough to survive summary judgment.
  • By the time a well-supported summary-judgment motion is heard, plaintiffs must:
    • Have retained an expert, and
    • Obtained and filed an expert affidavit (or otherwise presented sworn evidence) that establishes a prima facie case.
  • Last-minute, bare-bones responses seeking more time or more discovery will not suffice, especially in the absence of a properly supported Rule 56(f) affidavit.
  • Failure to act diligently can result in the permanent dismissal of the case at the summary-judgment stage, even if an expert could later be obtained.

The ruling effectively front-loads the need for expert engagement in Mississippi medical-malpractice litigation. Plaintiffs cannot rely on the expectation that trial courts will routinely grant them extra time after a summary-judgment motion has been fully briefed and set for hearing.

2. For Defendants and Defense Counsel

The decision strengthens the strategic value of early and well-documented summary-judgment motions in medical malpractice cases:

  • Defendants can move for summary judgment “at any time,” including relatively early in the case, so long as they support the motion with competent expert affidavits.
  • If the plaintiff does not respond with expert evidence by the hearing date, defendants have strong grounds to insist that summary judgment be granted then and there.
  • Defense counsel should carefully document:
    • The timing and service of their Rule 56 motion;
    • Compliance with Rule 56(c)’s notice requirements;
    • Any lack of expert designation or affidavit by the plaintiff; and
    • Any failure by the plaintiff to submit a Rule 56(f) affidavit.

This case provides a clear appellate blueprint for challenging trial court denials of summary judgment where plaintiffs have not timely produced expert testimony.

3. For Trial Courts

The opinion is also a firm reminder to circuit judges:

  • Rule 56(f) is not a loose, discretionary “do-over” mechanism. Its use must be grounded in a record showing:
    • Specific facts explaining the need for more time,
    • Concrete steps undertaken by the nonmovant, and
    • A finding of diligence and good faith.
  • Sua sponte extensions that lack an articulated basis and are unsupported by affidavits risk reversal and reversal with rendition of judgment for the moving party.
  • Trial courts should ensure that orders granting additional time under Rule 56(f):
    • Expressly reference the rule, where appropriate;
    • Summarize the factual showing made by the nonmovant; and
    • Contain explicit findings regarding diligence and good faith.

The Court’s willingness to grant interlocutory review and then reverse and render underscores its intent to enforce these procedural boundaries strictly.

4. On Mississippi Civil Procedure More Broadly

Beyond medical malpractice, the decision reinforces several broader principles:

  • Summary judgment is a serious, dispositive tool. Once a movant has supported a Rule 56 motion, the nonmovant must meet proof with proof.
  • Rule 56(f) is narrowly construed. Extensions are not automatic and must be justified by detailed, evidentiary showings.
  • Uniform Civil Rule 4.02, although “for the benefit of the trial judge,” is still relevant on appellate review. Persistent or unexplained delay in responding to motions may weigh against a nonmovant’s claim of diligence or good faith.

In this sense, Lakeland Premier fits within a trend of Mississippi appellate decisions emphasizing disciplined adherence to civil procedure rules and evidentiary burdens at the summary-judgment stage.

IV. Complex Concepts Simplified

A. Summary Judgment

Summary judgment is a procedure that allows a court to decide a case without a full trial if:

  • There is no genuine dispute about any material (outcome-determinative) fact, and
  • The moving party is entitled to judgment as a matter of law.

At this stage:

  • The court looks at evidence such as affidavits, deposition excerpts, and documents.
  • The court does not weigh credibility or resolve factual disputes; it decides whether a real, evidence-based dispute exists.
  • Mere allegations in the complaint are not enough; the nonmovant must present actual evidence.

B. Expert Affidavit and Expert Testimony

An expert affidavit is a written statement, sworn under oath, by a qualified expert (such as a physician) that sets out:

  • The expert’s qualifications;
  • The applicable professional standard of care;
  • How the defendant’s conduct did or did not meet that standard; and
  • Whether that conduct caused the plaintiff’s harm.

In medical malpractice cases, lay jurors typically lack the specialized knowledge to determine whether a doctor acted negligently. Expert testimony fills this gap and is therefore almost always required.

C. Certificate of Expert Consultation (§ 11-1-58)

Mississippi Code § 11-1-58(1)(a) requires plaintiffs to file a certificate of expert consultation with their complaint in medical-malpractice cases. This certificate:

  • Is executed by the plaintiff’s attorney;
  • States that the attorney has consulted at least one qualified expert; and
  • Represents that, based on that consultation, there is a reasonable basis for filing the suit.

Crucially:

  • The certificate is not itself expert evidence.
  • It is a threshold, gatekeeping device aimed at discouraging frivolous suits.
  • To survive summary judgment, plaintiffs still must present actual expert testimony (via affidavit or live testimony) at the appropriate time.

D. Rule 56(f) Continuances

Rule 56(f) of the Mississippi Rules of Civil Procedure allows a nonmoving party who is not yet ready to oppose a summary-judgment motion to request a delay. To use this rule properly, a party must:

  1. File an affidavit (or equivalent evidence) explaining:
    • What essential facts are missing,
    • Why those facts cannot be presented now, and
    • What has been done so far to try to obtain them.
  2. Demonstrate that they have acted diligently and in good faith.

If these showings are made, the judge may:

  • Postpone ruling on the motion,
  • Allow more time for discovery, or
  • Issue any other just order.

In Lakeland Premier, no such affidavit or factual showing was made, yet the trial court granted additional time. That is why the Supreme Court found an abuse of discretion.

E. “Reverse and Render” vs. “Reverse and Remand”

When an appellate court reverses and remands, it:

  • Overturns the lower court’s ruling, and
  • Sends the case back to the trial court for further proceedings, often with instructions.

When it reverses and renders, it:

  • Overturns the lower court’s ruling, and
  • Enters the judgment that the trial court should have entered, ending the case on the merits.

In this case, the Supreme Court reversed the denial of summary judgment and rendered judgment for the defendants, effectively dismissing Jackson’s claims against Lakeland Premier and Dr. Hardeman.

V. Conclusion

Lakeland Premier Women’s Clinic, PLLC and Natasha N. Hardeman, M.D. v. Lakisha Jackson is a significant reaffirmation and sharpening of Mississippi’s law on:

  • The indispensability of expert testimony in medical-malpractice cases at the summary-judgment stage; and
  • The strict, limited circumstances under which Rule 56(f) permits trial courts to continue or delay summary-judgment proceedings.

Key takeaways include:

  1. A certificate of expert consultation under § 11-1-58 does not substitute for actual expert testimony at summary judgment.
  2. Once a medical-malpractice defendant files a properly supported summary-judgment motion, the plaintiff must respond with sworn expert evidence; generalized allegations or discovery requests will not suffice.
  3. Rule 56(f) continuances require specific factual showings, demonstrable diligence, and good faith. Absent that, granting extra time is an abuse of discretion.
  4. Where a plaintiff fails to provide expert testimony establishing a prima facie case, summary judgment is required, and later-obtained expert affidavits cannot retroactively cure the failure if the original denial of summary judgment was legally erroneous.

In the broader legal landscape, this opinion signals that Mississippi’s appellate courts will continue to enforce rigorously both the substantive expert-evidence requirement in professional negligence cases and the procedural safeguards built into Rule 56. Plaintiffs must be prepared early; defendants who properly support their motions can expect serious consideration of summary judgment; and trial courts must document and justify any discretionary extensions under Rule 56(f), or risk reversal and rendition.

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