Celotex Corp v. Catrett

Brief Fact Summary. The Respondent, Catrett (Respondent), filed suit alleging that the death of her husband resulted from his exposure to products containing asbestos manufactured or distributed by 15 named corporations, including the Petitioner, the Celotex Corporation (Petitioner). Petitioner filed a motion for summary judgment, without offering any evidence contradicting Respondent’s claim that Respondent had failed to produce sufficient evidence supporting its claim.
Synopsis of Rule of Law. To survive a motion for summary judgment under Federal Rule of Civil Procedure (FRCP) Rule 56(c), the party with the burden of proof at trial must make showing sufficient to establish the existence of an element essential to that party’s case. Moreover, the party moving for summary judgment is not require to support its motion with evidence negating the opponents claim.

Facts. Respondent filed suit alleging that the death of her husband resulted from his exposure to products containing asbestos manufactured or distributed by 15 name corporations, including Petitioner. Petitioner’s filed a motion for summary judgment on the grounds that Respondent had failed to produce evidence that any of Petitioner’s products were the proximate cause of the injuries alleged. In response to the motion, Respondent produced three documents that she claimed demonstrate there is a genuine material factual dispute as to whether the decedent had ever been exposed to Petitioner’s asbestos products. The district court granted Respondent’s motion. The court of appeals Reversed.

Issue. This case concerns what a party with the burden of proof at trial must show in order to survive a motion for summary judgment under FRCP Rule 56(c).

Held. The Supreme Court of the United States (Supreme Court) reversed the court of appeals and remanded the case to the district court with an order to grant the motion for summary judgment. The plain language of FRCP Rule 56(c) mandates the entry of summary judgment, after adequate time for discovery, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case and on which that party bears the burden of proof at trial. In such a situation, there is no genuine issue as to any material fact, since a complete failure of proof concerning an essential element of the nonmoving party’s case necessarily renders all other facts immaterial The standard for granting summary judgment mirrors the standard for a directed verdict under FRCP Rule 50(a). FRCP Rule 56 does not require that the party moving for summary judgment support its motion with affidavits or other similar materials negating the opponent’s claim. The nonmoving party does not have to produce evidence in a form that would be admissible at trial in order to survive summary judgment, however, the burden on the moving party is discharged by pointing out to the court that there is an absence of evidence to support the nonmoving party’s case.

Dissent. Justice William J. Brennan (J. Brennan) dissented, in which he was joined by Justice Harry A. Blackmun (J. Blackman). J. Brennan’s dissent stressed that merely pointing out to the court that the party with the burden of proof at trial lacks sufficient evidence to support its claim is insufficient to warrant granting summary judgment. Instead, he would have held that the party seeking summary judgment must affirmatively demonstrate that there is no evidence in the record to support a judgment for the nonmoving party. Justice John Paul Stevens (J. Stevens) also dissented. His dissent is omitted by the casebook. Concurrence. Justice Byron R. White (J. White) concurred. J. White’s concurrence stressed that where the party with the burden of proof at trial does offer some evidence that could potentially place a material fact in issue, then the party moving for summary judgment is required to offer evidence negating the opposing party’s claim.

Discussion. The Supreme Court based its decision on the fundamental purpose of the summary judgment rule. That purpose being to dispose of claims or defenses unsupported by evidence before a trial begins and therefore saving the court system a needless trial. Thus, the Supreme Court will grant the motion whenever a party can point out to the court that the other party has no evidence supporting its claim, without requiring the party seeking summary judgment to disprove the opposing party’s claim.