Definition and Nature
Judgment on the pleadings is a judgment rendered based solely on the pleadings filed by the parties. It is one of the special forms of judgment. It is proper when the answer fails to tender an issue or otherwise admits the material allegations of the adverse party's pleading.
Basis for Judgment
The basis for rendering a judgment on the pleadings is that the answer fails to tender an issue or admits the material allegations in the adverse party's pleading. If an answer does not specifically deny the material allegations of the complaint, or if it denies them improperly, material averments are deemed admitted. An admission made in a pleading cannot be controverted by the party making it. A claim of ignorance or lack of information regarding plain allegations is not considered a specific denial and leads to an admission.
When Proper and Improper
Judgment on the pleadings is proper when the answer fails to tender an issue. It is also proper when the answer admits the material allegations in the adverse party's pleading. If the answer does not tender an issue or admits material allegations, judgment on the pleadings is appropriate because there is no factual issue left to be tried.
Judgment on the pleadings is improper when the answer tenders an issue. Conflicting allegations in the pleadings also make judgment on the pleadings improper. Where the answer fails to deny an issue, or otherwise admits material allegations, judgment on the pleadings is proper.
Initiation (Motu Proprio or Motion)
Judgment on the pleadings can be rendered by the court motu proprio or upon motion of a party. While the rule requires a motion, case law suggests the court may render judgment motu proprio.
Distinction from Summary Judgment
Judgment on the pleadings is distinguished from summary judgment. Judgment on the pleadings is based solely on the allegations in the pleadings. Summary judgment, on the other hand, is based upon supporting affidavits, depositions, or admissions presented with a motion, demonstrating that there is no genuine issue as to any material fact. Summary judgment goes beyond the pleadings by considering evidence.