Celotex Corp. v. Catrett

Brief Fact Summary.

Petitioner moved for summary judgment, arguing that Respondent had failed to produce evidence that its products had caused her husband’s death.

Synopsis of Rule of Law.

Under Rule 56, the moving party carries the burden of showing there is no genuine issue of martial fact within the pleadings, depositions, and interrogatories provided by the plaintiff, without providing additional evidence negating the plaintiff’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) filed a motion for summary judgment under Rule 56, arguing the Respondent had failed to produce sufficient evidence that their products caused the death, focusing on the fact that the Respondent had listed no witnesses for trial. In response, Respondent produced three additional documents naming potential witnesses. Petitioner argued these documents were hearsay.

Issue.

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

Held.

No, the moving party is not required to submit further evidence. The decision of the Court of Appeals is reversed and remanded.

Dissent.

Justice Brennan

Justice Brennan argued that the Petitioner did fail to meet its burden of identifying no genuine issue of material fact, based on the three additional documents submitted by the Respondent in response to the motion for summary judgment.

Concurrence.

Justice White

Justice White agreed with the Court’s opinion, but believed that whether or not the Respondent’s named witnesses were sufficient evidence to defeat the motion for summary judgment should be considered by the lower court on remand.

Discussion.

The Court determined, based on the language of and purpose of Rule 56 and precedent set by Adickes v. S.H. Kress & Co., that Petitioner was not required to provide evidence to support its motion for summary judgment. Here, the motion was properly based on pleadings, depositions, and interrogatories and it was error for the lower court to deny the motion without considering whether a genuine issue of material fact existed within these documents and transcripts.