Judgment Day (2009) - Aftermath

Aftermath

Following Randy Orton's retention of the WWE Championship against Batista at Judgment Day by getting himself intentionally disqualified, Ric Flair, an associate of Batista's, announced on the May 18 episode of Raw that, as ordered by the Raw General Manager, Vickie Guerrero, Orton would face Batista in a steel-cage match at Extreme Rules, which would prevent both interference from outside parties and deliberate disqualifications.

Also, on the May 18 episode of Raw, it was announced that The Big Show would have a rematch with his Judgment Day opponent, John Cena at Extreme Rules as well; this time, however, the match was to be a submission match, which a wrestler can only win by forcing an opponent to submit.

On the SmackDown immediately following Judgment Day, SmackDown general manager, Theodore Long, felt that Edge's retention of the World Heavyweight Championship was questionable due to Matt Hardy's interference, so he declared that Jeff Hardy would have a rematch for the championship at Extreme Rules. Hardy and Edge had a match that night, with the stipulation that whoever won would be allowed to choose the stipulation for the match at Extreme Rules. Hardy won the match, and chose a ladder match, which requires the competitors in the match to climb a ladder to obtain the title belt suspended over the ring in order to win.

After defeating CM Punk at Judgment Day, Umaga continued to attack Punk. He interfered in Punk's match with Chris Jericho on the May 22 episode of SmackDown, assaulting Punk with a leather strap, and issuing a challenge to Punk for a Samoan strap match at Extreme Rules.

After Christian retained the ECW Championship against Jack Swagger at Judgment Day, Swagger attacked Christian on the following episode of ECW and pushed him off the entrance ramp. Two days later, on Superstars, Swagger interfered in a title match between Christian and Tommy Dreamer, resulting in the match being ruled a no contest. On the May 26 episode of ECW, Swagger announced that he would have a rematch against Christian at Extreme Rules, but the ECW general manager, Tiffany, stated that Dreamer had been added to the match, making it a triple threat hardcore match, a match with no disqualifications or countouts, and the first man to score a pinfall or submission would win. As Dreamer's contract with the company was set to expire one day before the show, it was announced that he had signed a one-day extension to give him a chance at winning the title; if Dreamer were to fail to win the title, he would no longer wrestle for ECW.

Following Mysterio's victory over Jericho at the event, Jericho went to SmackDown general manager, Theodore Long, and demanded a rematch for the title the next month at Extreme Rules; Long would then announce that would happen in a No Holds Barred match at the event.