Rule 192.Summary Judgments—Multiple Issues

Article II. Rules on Civil Proceedings in the Trial Court · Part D. Motions for Summary Judgments and Evidentiary Affidavits · Not amended since adoption on record · Last verified July 20, 2026

In one sentenceRule 192 gives a court flexibility to postpone, enter, or enforce a partial summary judgment when it will not resolve every issue in the case.

Full Text of Ill. S. Ct. R. 192

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When the entry of a summary judgment will not dispose of all the issues in the case, the court may, as the justice of the case shall require, either (1) allow the motion and postpone the entry of judgment thereon; (2) allow the motion and enter judgment thereon; or (3) allow the motion, enter judgment thereon, and stay the enforcement pending the determination of the remaining issues in the case. If a party resisting the entry of a summary judgment relies upon an affirmative demand against the moving party for an amount less than the latter’s demand, judgment for the difference may be entered and enforced.

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Plain-English Summary

Not every summary judgment wraps up a whole case. When granting one will still leave other issues unresolved, Rule 192 gives the court three options depending on what justice calls for: hold off entering judgment on the resolved issue until the rest of the case catches up, enter judgment on that issue right away, or enter judgment and then stay enforcement while the remaining issues get worked out.

The rule also handles a specific wrinkle: if the party opposing summary judgment has its own smaller claim against the moving party, the court can enter and enforce judgment for the net difference between the two amounts, rather than requiring separate judgments to sort out who owes whom.

Frequently Asked Questions

What happens if summary judgment only resolves part of my case?

Rule 192 lets the court choose among postponing entry of judgment, entering it right away, or entering it but staying enforcement until the rest of the case is resolved.

Can a court enforce a partial summary judgment before the rest of the case is decided?

It can, but Rule 192 also lets the court stay enforcement of that judgment pending resolution of the remaining issues, if that better serves the case.

What if the party I am suing has a smaller counterclaim against me?

If summary judgment is entered against them but they have an affirmative demand for a lesser amount, the court can enter and enforce judgment for the difference between the two claims.

Who decides which of the three options under Rule 192 applies?

The trial court, based on what the justice of the case requires given the specific claims and posture of the litigation.

Does a partial summary judgment end the whole lawsuit?

No, by definition it resolves fewer than all the issues, and the remaining claims continue in the case unless and until they are separately resolved.

Committee Comments

This is former Rule 16 without change in substance.

Source & verification. Rule text, official Committee Comments, and amendment history are reproduced verbatim from the Illinois Supreme Court Rules, promulgated by the Supreme Court of Illinois. Last verified July 20, 2026. · Official source

Also known as: partial summary judgment illinoismultiple issue summary judgmentstaying enforcement of judgmentsummary judgment on some claimsnet difference judgment offsetting claim