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Celotex Corp. v. Catrett

Supreme Court of the United States · 1986 · Civil Procedure

Civil Proceduresummary judgmentRule 56burden of productionRule 56summary judgmentburden of productionabsence of evidence

Facts

Catrett sued multiple corporations, including Celotex, alleging that her husband's death resulted from exposure to asbestos-containing products manufactured or distributed by them. Celotex moved for summary judgment, arguing that Catrett had failed to produce evidence that any Celotex product was a proximate cause of the alleged injuries and noting that in interrogatory answers she had not identified witnesses who could testify to exposure to Celotex products. In response, Catrett produced three documents that she claimed showed exposure to Celotex products in Chicago during 1970-1971. The District Court granted summary judgment for Celotex, stating there was no showing that plaintiff was exposed to Celotex's product in the District of Columbia or elsewhere within the statutory period.

Issue

Whether a party moving for summary judgment must always support its motion with affidavits or other evidence negating the opponent's claim, or whether the movant may obtain summary judgment by pointing out that the nonmoving party lacks evidence on an essential element on which that party bears the burden of proof at trial.

Rule

Under Rule 56(c), after adequate time for discovery and upon motion, summary judgment must be entered 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. The moving party bears the initial responsibility of informing the district court of the basis for its motion and identifying the portions of the record that demonstrate the absence of a genuine issue of material fact, but Rule 56 does not require the movant to support the motion with affidavits or other materials negating the opponent's claim. Where the nonmoving party bears the burden of proof on a dispositive issue, the movant may discharge its burden by pointing out that there is an absence of evidence to support the nonmoving party's case. Once such a motion is made and supported as provided in Rule 56, the nonmoving party must go beyond the pleadings and designate specific facts showing a genuine issue for trial.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a federal negligence action in Denver, Nora Kim alleges that a scaffold made by Front Range Lift Systems caused her fall. After two years of discovery, Front Range moves for summary judgment, citing Nora's deposition, interrogatory answers, and admissions to argue that she has identified no witness or document linking its scaffold to the accident, but it submits no affidavit denying involvement.

How should the court rule on the argument that the motion is procedurally defective because Front Range offered no affidavit negating Nora's claim?

Explanation. Under the majority opinion, the moving party must inform the court of the basis for the motion and identify record materials showing the absence of a genuine issue of material fact. But Rule 56 does not require the movant to submit affidavits or other materials negating the opponent's claim. When the nonmoving party bears the burden of proof on the dispositive issue, the movant may discharge its burden by pointing out an absence of evidence supporting that essential element.