Short answer. Generally no. A motion attacking a pleading, order, judgment, or proceeding must include all objections then available, and any objection not included is deemed waived — so raising a new ground afterward is barred, except for a narrow set of defenses the Rules separately exempt from this waiver rule.

What the law says

a motion attacking a pleading, order, judgment, or proceeding shall include all objections then available, and all objections not so included shall be deemed waived.

Rule 15, Section 9 — Omnibus motion. Read the full provision →

The core omnibus motion principle

A motion attacking a pleading, order, judgment, or proceeding is expected under this rule to be genuinely comprehensive at the very time it is filed. The rule requires such a motion to include all objections then available to the movant at that point in time — not merely the single objection the movant happens to find most compelling or most convenient to raise first. This means a movant needs to take stock, before filing, of every available basis for attacking the pleading, order, judgment, or proceeding in question, rather than filing a bare-bones motion and hoping to supplement it with additional grounds down the road.

The waiver consequence

The consequence for leaving something out of that motion is stated directly and without much room for argument: all objections not so included shall be deemed waived going forward. This means a party generally cannot hold an available objection quietly in reserve, raise only part of what could genuinely have been included, and then attempt to bring up the rest later in a separate motion attacking that same pleading, order, judgment, or proceeding.

Why this rule exists

Without a rule like this one in place, a party could conceivably attack the very same pleading or proceeding piecemeal, filing one successive motion after another that each raises just one new ground, dragging the case out considerably through repeated, staggered challenges instead of consolidating every genuinely available objection into a single comprehensive motion filed at the very outset. This wastes both the court's time and the opposing party's resources responding again and again to what is, in substance, the same underlying attack.

A recognized carve-out

The waiver principle established here is not entirely absolute in every situation — the Rules separately exempt a narrow set of defenses that remain available even where they were not raised in an earlier motion, reflecting the reality that certain defects are considered serious enough that a party should not lose the ability to raise them simply through omission. Outside that narrow, specifically exempted category, however, the general waiver rule described above continues to fully control.

Related provisions

Note. Statute text quoted on this page is reproduced from the official enactment and is linked to the full provision. The explanation around it is general legal information from Vivas & Nobles Law Office, not legal advice. Whether it applies to your situation depends on facts only a lawyer reviewing them can assess.