Can a court order a judgment against a party for failing to file a statement required by local rule?

"Although authorized to impose sanctions for violation of local rules (Code Civ. Proc., 575.2, subd. (a)), courts ordinarily should avoid treating a curable violation of local procedural rules as the basis for crippling a litigant's ability to present his or her case. . . . [I]n the absence of a demonstrated history of litigation abuse, '[a]n order based upon a curable procedural defect [including failure to file a statement required by local rule], which effectively results in a judgment against a party, is an abuse of discretion.' [Citation.]" (Elkins v. Superior Court (2007)

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