Saturday, November 28, 2015

Celotex Corp v. Catrett case brief summary

Celotex Corp v. Catrett case brief
1986 SCOTUS

Posture: Trial court granted summary judgment, appeals reversed, SCOTUS reverses. 
Facts: Catrett’s husband died of exposure to products containing asbestos made by 15 of the named corporations. Defendant’s argued for summary judgment because of proximate cause issues; due to a lack of any evidence that plaintiff’s husband was exposed. Plaintiff showed three documents that included evidence to show that the husband was exposed to the asbestos products. The trial court granted summary judgment two years later because of a lack of any evidence that the plaintiff was exposed to any of Celotex's products that were supposedly causing asbestos. The Court of Appeals reversed because they thought that the defendant should have made an effort to provide its own evidence that summary judgment should be granted and plaintiff’s husband was not exposed. 
Reasoning: Summary judgment rule says to enter summary judgment after enough time for discovery and upon motion, against the party who fails to make a sufficient showing of the existence of an essential element to their case and on which burden of proof falls on them during the trial to prove that element. There is no language in Rule 56 that says that moving party has to negate opponents claim, only demonstrate the absence of any material facts. They demonstrate the absence of these facts by pointing to pleadings and depositions; they do not need any affidavits to show that they are not at fault. 
White Concurrence: The Moving party must always support its summary judgment claim, but they do not need to show the absence of a material fact with evidence or affidavits. But summary judgment burden must be met by moving party. He does not go into detailed analysis, just relies on Court of Appeals opinion not to go deeper into the case.
Brennan Dissent: Lack of clarity because the court did not say what exactly is needed of a party moving for summary judgment. He says that because the defendant did not meet the *burden of production*, the motion should be denied. 2 burdens of summary judgment: 1. The burden of production is initially on moving party and if satisfied, shifts to the other party and 2. The burden of persuading entitlement to summary judgment which stays on moving party. 

Thinks that a difference should be made between a party that bears the burden of persuasion at trial and party that does not bear that burden. Basically, if the burden of persuasion at trial is on moving party (plaintiff moves for summary judgment) then credible evidence is needed. If the burden of persuasion is on the non-moving party (defendant moves for summary judgment) then Rule 56 burden of production must be satisfied. This burden is satisfied by either negation or a demonstration of insufficient evidence in the plaintiff’s claim. The second way to discharge burden is trickier and needs more information and evidence. 

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