Short answer. It depends on whether a hearing is held. Without a hearing, submission occurs upon filing the last required pleading, brief, or memorandum, or when the period to file it expires; with a hearing, submission occurs upon its termination or the filing of the last required pleading.
What the law says
A case shall be deemed submitted for judgment: A. In ordinary appeals. 1) Where no hearing on the merits of the main case is held, upon the filing of the last pleading, brief, or memorandum required by the Rules or by the court itself, or the expiration of the period for its filing. 2) Where such a hearing is held, upon its termination or upon the filing of the last pleading or memorandum as may be required or permitted to be filed by the court, or the expiration of the period for its filing.
Rule 51, Section 1 — When case deemed submitted for judgment. Read the full provision →
No hearing: submission tracks the last filing
Section 1 lays out precise triggers for when a case is ready for judgment. For an ordinary appeal where no hearing on the merits of the main case is held, submission happens upon the filing of the last pleading, brief, or memorandum required by the Rules or by the court itself, or the expiration of the period for its filing.
With a hearing: submission follows its conclusion
Where the appeal does involve a hearing on the merits, the trigger shifts: submission occurs upon its termination or upon the filing of the last pleading or memorandum as may be required or permitted to be filed by the court, or the expiration of the period for its filing. Whichever of those events comes last effectively marks submission for judgment.
Why pinning down submission matters
Because the case is only ready for judgment once these conditions are met, a party tracking an ordinary appeal should identify whether a hearing was held and, either way, confirm whether every required pleading, brief, or memorandum has actually been filed — or its filing period has lapsed — before assuming the case is already awaiting decision by the court.
This section also covers original actions
Rule 51, Section 1 does not stop at ordinary appeals; it separately addresses when original actions and petitions for review are deemed submitted, using a similar structure keyed to comments, hearings, and required pleadings — reflecting how the same submission concept applies across the different kinds of cases the Court of Appeals decides, whether they arrived by appeal or as an original filing brought straight to the court.
Submission does not end the case's activity entirely
Being deemed submitted for judgment fixes the point from which the court's own decision-making period is measured, but it does not necessarily bar every subsequent filing outright — a court can still, in appropriate circumstances, call for additional pleadings or clarification even after submission. What submission does establish clearly is the baseline record the court intends to decide the case on, absent some further order reopening the matter for more material.
Related provisions
- Rule 51, Section 1 — When case deemed submitted for judgment
- Rule 51, Section 2 — By whom rendered
- Rule 51, Section 4 — Disposition of a case