Celotex Corp. v. Catrett

Brief Fact Summary.

Catrett sued Celotex, as a  distributor or manufacturer of asbestos, seeking damages after her husband’s death, allegedly due to exposure to asbsestos. Celotex moved for summary judgment, based on lack of evidence of causation. Catrett produced three documents that she asserted established a genuine issue of material fact on the issue. The district court granted summary judgment in Celotex’s favor; the Court of Appeals reversed. The Supreme Court granted certiorari.

Synopsis of Rule of Law.

On a motion for summary judgment, the nonmoving party is entitled to judgment as a matter of law if the movant has failed to make a sufficient showing on an essential element of her case as to which she has the burden of proof. The moving party does not have to support its motion with affidavits or other supporting evidence to negate the nonmovant’s claim.

Facts.

Catrett sued Celotex, asserting claims for negligence, breach of warranty, and strict liability. She sued Celotex, as a  distributor or manufacturer of asbestos;  Catrett’s complaint asserted that her husband’s death was caused by exposure to asbsetos. Celotex moved for summary judgment, based on lack of evidence of causation. In response to the motion, Catrett produced three documents that she asserted established a genuine issue of material fact on the issue. The district court granted summary judgment in Celotex’s favor; the Court of Appeals reversed. The Supreme Court granted certiorari.

Issue.

Did the Court of Appeals err in reversing the district court’s grant of summary judgment in Celotex’s favor.

Held.

Yes. The Supreme Court reversed the Court of Appeals’ decision, and remanded the matter for further proceedings consistent with its decision.

Dissent.

Justice Brennan

The dissent argued that Celotex had not met its burden of production under Federal Rule of Civil Procedure 56; Celotex was not free to ignore the supporting evidence that the record contained.

Concurrence.

Justice White

Justice White stated that it is not enough for a defendant to move for summary judgment without supporting the motion or with a conclusory allegation that the nonmovant plaintiff has no evidence to prove her case; he agreed that remand was necessary since the Court of Appeals did not address the aspect of the case that involved plaintiff’s alleged witness who plaintiff asserted could support her claim.

Discussion.

A summary judgment motion can be made with or without supporting affidavits. Where the nonmovant has the burden of proof on a dispositive issue at trial, the summary judgment motion can rely on the pleadings and discovery. The Court of Appeals held that Celotex’s failure to support its motion with evidence tending to negate the alleged asbestos exposure precluded summary judgment in its favor. Since the Court of Appeals did not address either the adequacy of Catrett’s showing in opposition to Celotex’s motion, or the question of whether such a showing, if reduced to admissible evidence, would be sufficient to carry her burden at trial, remand was necessary.