Celotex Corp. v. Catrett

Brief Fact Summary. Celotex Corporation (Petitioner) appeals a judgment of the United States Court of Appeals for the District of Columbia Circuit reversing summary judgment in favor of the Ms. Catrett (Respondent) on the basis that the Respondent had not offered sufficient evidence rebutting Petitioner’s allegations.

Synopsis of Rule of Law. Summary judgment must be entered against a party who fails to make a showing of sufficient facts to establish the existence of an essential element of the case and which bears the burden of proof at trial.

Facts. Petitioner commenced this action alleging the wrongful death of her husband, which resulted from his exposure to products containing asbestos manufactured and distributed by the Respondent. Petitioner’s complaint alleged negligence, breach of warranty and strict liability. Respondent filed a Motion for Summary Judgment on the grounds that the Petitioner failed to produce evidence that any of Respondent’s products were the proximate cause of the injury. In response to Respondent’s Motion for Summary Judgment, Petitioner produced three documents, which she claimed demonstrated that there is a material issue of fact as to whether the decedent was exposed to Respondent’s asbestos. The district court granted Respondent’s Motion for Summary Judgment against the Petitioner, because Petitioner was unable to produce evidence in support of her allegation of wrongful death. Petitioner’s complaint alleged that the wrongful death of the Petitioner was a result of being exposed to Respondent’s asbestos products. The court of appeals reversed and held that Respondent’s failure to support the motion with evidence tending to negate such exposure of asbestos products precluded the entry of summary judgment in its favor.

Issue. Whether summary judgment must be entered against a party who fails to make a showing of sufficient facts to establish an element of the case?

Held. No. Judgment is reversed and the case is remanded for further proceedings consistent with the opinion. Under Rule 56 of the Federal Rules of Civil Procedure, summary judgment is proper if the pleadings, depositions, answers to interrogatories, admissions, and affidavits show that there is no genuine issue of material fact and that the moving party is entitled to judgment. In other words, if there is a genuine issue of material fact, then the case must proceed to the trier of fact. The party seeking summary judgment has the initial burden of informing the court of the basis for the motion. However, there is no express or implied requirement in Rule 56 that the moving party support its motion with affidavits negating the opponent’s claim. Parties may move for summary judgment with or without supporting affidavits. The language in the Adickes v. S.H. Kress & Co., 398 U.S. 144 (1970), should not be construed to mean that the burden is on the moving party to produce evidence showing the absence of genuine issue of material fact. Instead, the burden on the moving party may be discharged by showing that there is an absence of evidence to support the nonmoving party’s case. In the instant case, Respondent failed to show that there was an absence of evidence to support the nonmoving party’s case. However, the court determined that the court of appeals is better situated to answer the question of whether Petitioner made an adequate showing of exposure to asbestos products.

Dissent. The case required the Court to determine whether Respondent satisfied the initial burden of production in moving for summary judgment on the ground the Petitioner lacked evidence to establish and essential element of her claim. The Court has not clearly explained what is required of the moving party seeking summary judgment. Respondent did not meet its burden of production under Rule 56. Concurrence. Agree that the Court of Appeals was wrong to conclude that the moving Respondent must support his motion with evidence or affidavits showing the absence of a genuine dispute of fact. The movant must discharge the burden summary judgment places on it by demonstrating that there is an absence of evidence to support the nonmoving party’s case. Agree that the case should be remanded for further proceedings.

Discussion. This case overrules the decision in Adickes v. S.H. Kress & Co., which held that the movant in summary judgment motions have the burden to demonstrate evidence of the absence of a material issue of fact.