Summary of Celotex Corp. v. Catrett, U.S. Supreme Ct. (1986)
Cause of action: The following is a cause of action for reversal of summary judgment ruling, as it pertains to a wrongful death suit.
Procedural History: U.S. District Court for D.C. Granted summary judgment for petitioner against respondent b/c latter was unable to produce evidence in support of her allegation that her wrongful death complaint that the decedent had been exposed to petitioner’s asbestos products. Court of Appeals for D.C. Circuit reversed, and held that petitioner’s failure to support its motion with evidence tending to negate such exposure precluded the entry of summary judgment in its favor. This Court reverses the Appeals Court’s decision and remands.
Facts: Complaint filed for breach of warranty and strict liability. 2 DF’s filed motions challenging personal jurisdiction, while the other 13 filed for SJ. Petitioners said PL failed to provide evidence that the product was proximate cause. Respondent then produced 3 documents which claimed a material issue of fact — was a letter from a former worker for petitioner, as well as a letter from insurance company to petitioner.
Trial court’s grant of SJ centered primarily around respondent’s claim was not proven within the Statute of Limitations. The decision was reversed b/c Petitioner introduced no affidavits or otherwise to support its motion.
Issue(s): Under FRCP 56, was the D.C. Circuit for the Court of Appeals proper in reversing summary judgment on the grounds that petitioner’s summary judgment motion was rendered “fatally defective” when petitioner made no effort to adduce any evidence, in the form of affidavits or otherwise, to support its motion?
Court’s Rationale/Reasoning: This Court goes by the plain meaning of the rule, which they determine to mean that since a complete failure of proof concerning an essential element of the nonmoving party’s case renders all other facts immaterial, there can be “no genuine issue as to any material fact.” When nonmoving party has failed to make a sufficient showing on an essential element of her case.
Party seeking SJ must bear the initial responsibility of informing the court on the basis for its motion, identifying those parts of the pleadings, depos or answers to interrogatories, and admissions on file, together with affidavits, if any. The Court says there is no specific requirement in 56(c) as to affidavits or depositions (the rule says “if any”). 56(a) & (b) add “with or without supporting affidavits.” Respondent contends that under 56(e), petitioner cannot just rest on the laurels of his denials to the allegations. But 56(a) & (b) again refute this argument.
56(e) does not mean that the nonmoving party must actually produce evidence, they must merely point to the evidence submitted and provide reasons for SJ from it that there is no material issue of fact, as long as it is the nonmovant is not pointing to the pleadings themselves. Court of Appeals should have looked at respondent’s evidence produced in the trial court to see if either petitioner’s claim was warranted based on what it pointed out or that the evidence itself could demonstrate that there was a material issue of fact.
Rule: FRCO 56(c), 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.” Also see FRCP 56(e).
Holding: No. FRCP 56 must be construed with due regard not only for the rights of persons asserting claims and defenses tried to a jury, but also for the rights of persons opposing such claims and defenses to demonstrate in the manner provided by the Rule, prior to trial, that the claims and defenses have no factual basis.
Concurring: (White): “It is not enough to move for SJ w/o supporting the motion in any way or with a conclusory assertion that the PL has no evidence to prove his case.” The Court of Appeals should review the contention that respondent is or is not required to reveal her witnesses and evidence to determine if SJ should apply.
Dissenting: (Brennan, Chief Justice, Blackmun): What is required of the moving party seeking SJ on the ground that the nonmoving party cannot prove its case. Celotex did not meet its burden of production under FRCP 56. 2 elements for SJ: (1) burden of production which can shift to the other party if satisfied by the moving party, and (2) burden of persuasion which always remains on the moving party. #2 does not get analyzed unless #1 has been initially discharged.