Celotex Corp. v. Catrett
477 U.S. 317, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986).
-Catrett (P) sued Celotex (D) and several other asbestos manufacturers in federal district court, claiming that Catrett's husband’s death was caused by exposure to these products.
-Celotex moved for summary judgment on the grounds there was no evidence to prove that Catrett’s husband had been exposed to Celotex’s asbestos products.
-Afterwards, Catrett produced 3 documents as evidence that her husband had been exposed to Celotex products.
-Celotex objected to these documents (hearsay).
-The district court sustained Celotex's objection and granted Celotex’s summary judgment motion.
-The Court of Appeals reversed the lower court's ruling, holding that summary judgment was precluded because Celotex had failed to support its summary judgment motion with affidavits or other evidence that tends to show that the decedent had not been exposed to its products, as required by Civil Procedure Rule 56(e).
-The Supreme Court granted certiorari.
- When is summary judgment under Rule 56(c) proper?
- When is the grant of summary judgment under Rule 56(c) mandated?
- Must the party moving for summary judgment support its motion with affidavits?
- Should the Court of Appeals determine whether a showing by a party opposing summary judgment, if reduced to admissible evidence, would be sufficient to carry that party’s burden of proof at trial?
- Summary judgment under Rule 56(c) is proper if the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits (if any) show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.
- Rule 56(c) mandates the entry of summary judgment 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 will bear the burden of proof at trial.
- No. There is no express or implied requirement in Rule 56 that the moving party support its motion with affidavits.
- Yes. Whether a showing by a party opposing summary judgment, if reduced to admissible evidence, would be sufficient to carry that party’s burden of proof at trial should be determined by the Court of Appeals in the first instance.
-The amendment to 56(e) was made solely to broaden the scope of summary judgment motions by precluding the opposing party from referring only to its pleadings.
-On the other hand, the ruling by the Court of Appeals makes summary judgment more difficult to obtain and is in direct contradiction to the standards that are imposed by FRCP 56(e).
-Catrett did not meet her burden to show that the defendant had some level of culpability. The plaintiff did not establish a genuine issue of material fact and the grant of summary judgment was proper.
Reversed and remanded.
Concurrence (Justice White)
The party moving for summary judgment need not always support its motion with sufficient rebuttal evidence. Nevertheless, the moving party may not simply discharge its burden by asserting that the other party has no evidence to prove her case. The Court of Appeals must consider if the plaintiff revealed sufficient evidence to defeat the motion.
Dissent (Justice Brennan)
The Court has not clearly explained what must be shown by the party moving for summary judgment on the grounds that the non-moving party cannot prove its case.
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