Celotex Corp. v. Catrett

Brief Fact Summary.

Woman sues asbestos company for allegedly causing the death of her husband from asbestos. The company moves for summary judgement claiming the wife did not show that her husband was exposed to their products, and the wife counters with three documents to prove that he was. The district court still grants the motion for summary judgement and the court of appeals reverses.

Synopsis of Rule of Law.

The moving party in a motion for summary judgement does not need to provide affirmative evidence in the form of affidavits to support its motion.

Facts.

Plaintiff Catrett sues asbestos companies for allegedly causing the death of her husband because he was exposed to their products. Defendant Celotex moved for summary judgement claiming that Plaintiff Catrett failed to present evidence that her husband was exposed to Celotex’s products. In response, Plaintiff Catrett submitted three documents that suggested her husband was exposed to Celotex’s products. The district court granted Defendant’s motion for summary judgement because Plaintiff Catreet lacked sufficient evidence to show that her husband was exposed to Celotex’s products in the District of Columbia or elsewhere. The court of appeals reversed on the ground that Defendant Celotex had not offered any evidence to support its motion for summary judgement.

Issue.

Does the moving party in a motion for summary judgement need to provide affirmative evidence in the form of affidavits to support its motion?

Held.

No, the moving party in a motion for summary judgement does not need to provide affirmative evidence in the form of  affidavits to support its motion. The judgement of the court of appeals is reversed and the matter is remanded.

Concurrence.

Justice Justice White concurring

The movant in a motion for summary judgement must support the motion in some way. Conclusory allegations are insufficient.

Justice Justice Brennan with The Chief Justice and Justice Blackmun dissenting

If the burden of persuasion is with the non-moving party, the moving party can request summary judgement by either (1) submitting affirmative evidence disproving an essential element to the claim or (2) demonstrating that the evidence is insufficient. The second path is what Defendant Celotex took, but its motion cannot succeed with conclusory statements. While affirmative evidence is not required to succeed in the second option, and affirmative showing of the absence of evidence is necessary. Defendant Celotex did not meet its burden of showing that Plaintiff Catrett’s evidence was insufficient to support her claim.

Discussion.

FRCP 56(c) directs courts to grant a motion for summary judgement after adequate time for discovery and upon a motion, against a party that fails to establish the existence of an element essential to that party’s case that it bears the burden of proving at trial.
Summary judgement serves as a tool for parties to have a just, speedy, and inexpensive resolution to their disputes.
The moving party need only to inform the court of the reason why the motion should be granted by pointing to those parts of the lawsuit lacking a genuine issue of material fact. FRCP 56 does not require the movant to provide affirmative evidence to support its motion.
The court of appeals was mistaken in assuming the movant had this burden of providing affirmative evidence to support its motion because FRCP 56 does not require it.
While the moving party is not required to present affirmative evidence, the non-moving party is expected to present affirmative evidence to overcome the challenge.
The court of appeals should have looked at Plaintiff Catrett’s evidence from the trial court to see if her claim that summary judgement should not have been granted was warranted.
The judgement of the court of appeals is reversed and the matter is remanded.