Celotex Corp. v. Catrett

Brief Fact Summary.

Petitioner moved for summary judgment under Rule 56, arguing the Respondent had failed to produce evidence of proximate cause.

Synopsis of Rule of Law.

Under Rule 56, the moving party has the burden of identifying that the pleadings, depositions, answers to interrogatories, and admissions on file show no genuine, triable issue of material fact. However, the moving party is not required to submit further evidence negating the opponent’s claim.

Facts.

Catrett (Respondent) sued multiple corporations for the death of her husband, claiming he was exposed to products containing asbestos manufactured or distributed by the corporations. One of the corporations, Celotex Corp. (Petitioner) moved for summary judgment under Rule 56, arguing the Respondent had failed to produce evidence of proximate cause. In response, Respondent produced three additional documents. Petitioner argued these documents were inadmissible.

Issue.

Is a motion for summary judgment improper if the moving party provides no evidence to support the motion?

Held.

No, the moving party is not required to submit further evidence negating the opponent’s claim on a motion for summary judgment. Reversed and remanded.

Dissent.

Justice Brennan

Justice Brennan argued that the Petitioner failed to meet its burden of identifying no genuine issue of material fact, given the additional documents submitted by the Respondent.

Discussion.

The Court determined that under Rule 56, Petitioner was not required to provide evidence in the form of affidavits to support its motion for summary judgment.