Celotex Corp. v. Catrett – Case Brief Summary

Summary of Celotex Corp. v. Catrett, 477 U.S. 317, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986).

Facts

Catrett (P) sued Celotex (D) and several asbestos manufacturers in federal district court, claiming that her husband’s death was caused by exposure to their 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. Catrett then produced three documents as evidence that her husband had been exposed to Celotex products. Celotex objected to the documents on the grounds that they were hearsay. The district court sustained the objection and granted Celotex’s motion for summary judgment.

The Court of Appeals reversed, holding that summary judgment was precluded because Celotex failed to support its motion with affidavits or other evidence tending to show that the decedent had not been exposed to its products, as required by Federal Rule of Civil Procedure 56(e). The Supreme Court granted certiorari.

Issues

  1. When is summary judgment under Rule 56(c) proper?
  2. When is the grant of summary judgment under Rule 56(c) mandated?
  3. Must the party moving for summary judgment support its motion with affidavits?
  4. 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?

Holding and Rule (Rehnquist)

  1. Summary judgment under Rule 56(c) is proper if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the 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.
  2. 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.
  3. No. There is no express or implied requirement in Rule 56 that the moving party support its motion with affidavits.
  4. 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.

A party moving for summary judgment does not necessarily bear the burden of supplying evidence showing the absence of a genuine dispute regarding a material fact. The moving party merely bears the burden of informing the court of the basis for its motion. The moving party may show the absence of evidence supporting the nonmoving party’s case.

Legislative Purpose

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. The ruling by the Court of Appeals on the other hand makes summary judgment more difficult to obtain and is in direct contradiction to the standards 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.

Disposition

Reversed and remanded.

Concurrence (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 (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.

See Dioguardi v. Durning for a law school civil procedure case brief holding that a complaint need only put the court and defendant on notice of the cause of action to withstand summary judgment.


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