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Celotex Corp. v. Catrett

(1986)

Supreme Court of the United States - 477 U.S. 317, 106 S.Ct. 2548, 477 U.S. 317, 91 L. Ed. 2d 265, 106 S. Ct. 2548, 1986 U.S. LEXIS 118, SCDB 1985-128

tl;dr:

When a defendant moves for summary judgment, they must meet the burden of showing that the non-movant lacks sufficient facts.

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Case Summary

In Celotex Corp. v. Catrett (1986), the Supreme Court ruled on a crucial case concerning summary judgment motions in civil litigation. This case had reached the federal judiciary's highest level, as it reviewed a circuit court's decision upholding a district court's summary judgment grant in favor of defendant manufacturer Celotex. The plaintiff, Catrett, sued several asbestos manufacturers, including Celotex, in federal district court, alleging that her husband died from exposure to their products. Celotex sought summary judgment, arguing that Catrett failed to provide evidence supporting her claim.

Catrett presented documents showing her husband had worked around asbestos products, potentially manufactured by Celotex. However, Celotex claimed these documents were insufficient and inadmissible hearsay. The district court agreed with Celotex, and the circuit court affirmed that Celotex showed no genuine issue of material fact existed due to Catrett's lack of evidence. The case then went to the Supreme Court.

The central issue was whether a party seeking summary judgment had to provide evidence countering their opponent's claim or simply point out their opponent's lack of evidence. The Supreme Court reversed the circuit court's decision, ruling that the moving party did not need to counter the opponent's claim, but could show their opponent lacked evidence. The Court interpreted Rule 56, which governs summary judgment motions, as not requiring evidence, but only a demonstration that there was no genuine issue of material fact.

Once the moving party met its initial burden, the burden shifted to the nonmoving party to provide specific facts proving a genuine issue for trial. The case was sent back for further proceedings in line with this ruling.

This case is significant because it established a clear standard for summary judgment motions, clarified party burdens, and promoted judicial efficiency by enabling meritless claims and defenses to be disposed of more swiftly.

ICRAIssue, Conclusion, Rule, Analysis for Celotex Corp. v. Catrett

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Facts & HoldingCelotex Corp. v. Catrett case brief facts & holding

Facts:Catrett sued a number of asbestos manufacturers/distributors in district court,...

Holding:Under FRCP 56, the party motioning for summary judgment does...

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Celotex Corp. v. Catrett | Case Brief DeepDive
Majority opinion, author: Justice Rehnquist
Level 1
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Celotex Corporation filed a motion for summary judgment in a wrongful-death complaint involving asbestos exposure, arguing that the plaintiff failed to produce evidence that Celotex's products were the proximate cause of the injuries alleged. The District Court granted summary judgment in favor of Celotex, but the Court of Appeals for the District of Columbia Circuit reversed the decision, stating that Celotex's failure to provide evidence negating exposure precluded summary judgment. The Supreme Court clarified that summary judgment is appropriate if a party fails to establish an essential element of their case, on which they bear the burden of proof at trial. The moving party must identify portions of the evidence that demonstrate the absence of a genuine issue of material fact, but there is no requirement for the moving party to support its motion with affidavits or other similar materials negating the opponent's claim. Rule 56(e) requires the nonmoving party to go beyond the pleadings and designate specific facts showing that there is a genuine issue for trial, either through her own affidavits or through the depositions, answers to interrogatories, and admissions on file.

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Opinion (Concurrence), author: Justice White
Level 1
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In this case, Justice White agrees that the Court of Appeals was wrong in requiring the defendant to always provide evidence to prove the absence of a factual dispute. The defendant can rely on depositions, answers to interrogatories, and other evidence to demonstrate the plaintiff's inability to prove their case. However, the defendant must still meet the burden of proof required by the Rules and cannot simply make a conclusory assertion. The plaintiff is not required to reveal their evidence or witnesses unless ordered to do so by the court or discovery Rules. It is the defendant's responsibility to disprove the basis of the suit. Celotex argues that summary judgment cannot be granted without showing that the witness's testimony does not raise any genuine issue of material fact. However, Celotex claims that the respondent has failed to produce any basis for her case. The respondent argues that she has revealed enough evidence to defeat the motion for summary judgment and acknowledges her obligation to reveal her witnesses and evidence. The case is being remanded for further proceedings as the Court of Appeals did not address this issue.

Dissenting opinion, author: Justice Brennan
Level 1
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The Court was tasked with determining whether Celotex met its burden of production in moving for summary judgment on the grounds that the plaintiff lacked evidence to establish an essential element of her case at trial. The moving party seeking summary judgment must make a prima facie showing that it is entitled to summary judgment. If the burden of persuasion at trial would be on the non-moving party, the party moving for summary judgment may satisfy Rule 56's burden of production in two ways. First, the moving party may submit affirmative evidence that negates an essential element of the nonmoving party's claim. Second, the moving party may demonstrate to the court that the nonmoving party's evidence is insufficient to establish an essential element of the nonmoving party's claim. If the moving party seeks summary judgment on the ground that the nonmoving party has no evidence, they must affirmatively show the absence of evidence in the record. The moving party must affirmatively demonstrate that there is no evidence in the record to support a judgment for the nonmoving party. Justice Brennan dissents from the Court's judgment in this case because he believes that the Court has not clearly explained what is required of a moving party seeking summary judgment, which may create confusion for district courts routinely deciding summary judgment motions.

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Dissenting opinion, author: Justice Stevens
Level 1
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The District Court erred in granting summary judgment to Celotex based on the lack of exposure in the District of Columbia, without considering the evidence of exposure in Illinois presented by the respondent. The Court of Appeals reversed the decision, noting the inconsistency in the District Court's opinion. Celotex failed to meet its burden of proof, and the "or elsewhere" language did not justify the summary judgment. Justice Stevens dissented from the Court's decision, and the reversal should still be affirmed on the narrow ground of the District Court's error.

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