Celotex Corp. v. Catrett

477 U.S. 317 (1987)

What's Going On?

Petitioner appeals from an appellate court decision reversing a grant of summary judgment in an action where Respondent alleges that her husband died resulting from exposure to Petitioner's asbestos products.

Who's Who?

Petitioner     :

Celotex Corp. – (original defendant) manufacturer of products containing asbestos.

Respondent :

Catrett – (original plaintiff) administratrix of the estate of her husband, who died form exposure to asbestos in Petitioner's product.

Facts:

Respondent Catrett sued fifteen named corporations, including Petitioner Celotex Corp., alleging that exposure to asbestos contained within their products was responsible for her husband's death. Petitioner moved for summary judgment, arguing that Respondent had failed to produce any evidence showing that Petitioner's products were a proximate cause of the alleged injuries. Respondent then produced three documents tending to establish that her deceased husband had been exposed to Petitioner's asbestos products. The district court granted Petitioner's motion to dismiss on the ground that there was no showing that Respondent's deceased husband was exposed to Petitioner's product. The appellate court reversed because Petitioner failed to support its motion for summary judgment with affidavits or other similar materials negating Petitioner's claim.

Issue:

Is a party seeking summary judgment required to support its motion for summary judgment with affidavits or other similar materials negating the opposing party's claim?

Decision:

No. FRCP 56(c) requires the court to enter summary judgment against a party who fails to make a showing sufficient to establish the existence of an essential element of that party's case upon which that party will bear the burden of proof at trial. Where a party fails to prove an essential element of its case, all other facts become immaterial, and the party seeking summary judgment is entitled to summary judgment. The party seeking summary judgment bears the initial responsibility of informing the district court of the basis for its motion, and demonstrating the factors which it believes show the absence of a genuine issue of material fact; however there is no requirement in Rule 56 that the moving party support its motions with supplemental materials negating the opponent's claim. Requiring such materials would detract from one of the principal purposes of Rule 56, which is to isolate and dispose of factually unsupported claims or defenses. The nonmoving party may oppose a motion for summary judgment by producing any of the types of evidentiary materials listed in Rule 56(e), except the mere pleadings themselves. In making its determination, the appellate court in this case relied on the language in Adickes v. S. H. Kress & Co., which it incorrectly interpreted to mean that the party moving for summary judgment has the burden of showing the absence of a genuine issue of material fact. The correct interpretation of Adickes is that 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. Because the present action had commenced one year before the motion for summary judgment was filed, and both parties had conducted discovery, there is no serious claim that Respondent was unduly inconvenienced by a premature motion for summary judgment. In this case, the appellate court failed to address whether Respondent made an adequate showing of the decedent's exposure to Petitioner's products, and whether such a showing should have been required. Because the appellate court is better equipped to make these determinations than this court, the case is reversed and remanded.

Basic Rule:

A party may be entitled to summary judgment by showing that the party bearing the burden of persuasion at trial will not be able to prove an element essential to its case, based on the record.

Concurrence:

This case was correctly decided, but the party moving for summary judgment is still required to discharge the burden that the rules place upon him by supporting the motion with more than a conclusory allegation that the plaintiff has no evidence to prove his case. If Respondent names a witness to support her claim, Petitioner must somehow show that the possible testimony of the witness raises no genuine issue of fact.

Dissent:

Although the majority's legal analysis is correct, its decision does not give sufficient guidance to the district courts. If the burden of persuasion is on the nonmoving party, the moving party may satisfy Rule 56's burden of production by submitting affirmative evidence that negates an essential element of the nonmoving party's claim, or the moving party may demonstrate that the nonmoving party's evidence is insufficient to establish an essential element of the nonmoving party's claim. Either way, the moving party must affirmatively demonstrate that there is no evidence in the record to support a judgment for the nonmoving party. The nonmoving party may defeat a motion for summary judgment that asserts the nonmoving party has no evidence by alerting the court to supporting evidence that was overlooked or ignored by the moving party.

Terms:

Administratrix :

Feminine form of administrator – a person appointed by the court for the purposes of managing the assets of one who died without leaving a will.

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