Celotex Corporation v. Catrett
SCOTUS -1986 (477 U.S. 317)
- P claimed that her husband died because of exposure to D's asbestos products.
- D filed for summary judgment in District Court arguing that P had failed to produce any evidence that any of the D's products were the proximate cause of the injuries.
- P responded by producing 3 documents all tending to establish that P's husband had been exposed to D's asbestos products in Chicago during 1970-1971.
- D argued that the three documents were inadmissible hearsay and could not be considered in opposition to the summary judgment motion.
- District Court granted D's motion for summary judgment.
- Circuit Court reversed (D made no effort to adduce any evidence to support its motion)
- SCOTUS reversed, D's motion for summary judgment granted.
- Does the movant of a summary judgment motion have to provide any evidence (i.e. affidavits) to support its motion?
- A movant of a summary judgment motion does not have to provide any evidence to support its motion; it need only show that the opposing party lacks sufficient evidence to support its case.
- Parties do not have to supply evidence in a form that would be admissible at trial to affect/avoid summary judgment.
- Summary judgment 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.
- Rules 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.
- There is no express or implied requirement in Rule 56 that the moving party support its motion with affidavits or other similar materials negating the opponent's claim.
- 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.
- Rule 56(f) protects nonmoving parties from being railroaded by summary judgment motions by allowing the motion to be denied if the nonmoving party has not had an opportunity to make full discovery.
- The evidence of the case seems to show that the P had enough evidence to show a genuine issue of material fact.
- The same motion had been made before by the D.