On May 4, 2026, the New Jersey Appellate Division, in a published opinion, prohibited successive motions for reconsideration of a final order. In the case, Doglio v. Boasso Am. Corp., the trial court granted the defendant’s motion for summary judgment, disposing of all claims as to all parties. The plaintiff filed a motion for reconsideration under Court Rule 4:49-2 within twenty days of the grant of summary judgment, which the trial court subsequently denied. After the denial of the motion for reconsideration and with nothing pending, the trial court sua sponte reconsidered the grant of summary judgment as well as its denial of the motion for reconsideration. As a result, the trial court reinstated the matter for trial.

The Appellate Division, in reversing the trial court, held that a motion for reconsideration of a final order must be filed within twenty days of that order under Rule 4:49-2. Once a motion for reconsideration of a final order is denied, neither the trial court, on its own initiative, nor a party may take any action to vacate that final order. The opinion also clarified that the denial of a motion for reconsideration does not create a “new final judgment” subject to reconsideration under Rule 4:49-2.

The opinion focused on the principles favoring a policy of finality in summary judgment orders. Specifically, the Appellate Division cautioned that “[a]llowing a never-ending sequence of motions for reconsideration jeopardizes that policy and undermines the finality Rule 4:49-2 was designed to secure.”

The Doglio opinion firmly establishes the principle that “repetitive bites at the apple” swiftly sour the core. In this precedential opinion, the Appellate Division’s holding will limit the extent of post final-judgment motion practice and provide finality to parties.