Celotex Corp. v. Catrett

SCOTUSCase
Litigants=Celotex Corp. v. Catrett
ArgueDate=April 1
ArgueYear=1986
DecideDate=June 25
DecideYear=1986
FullName=Celotex Corporation v. Catrett, Administratrix of the Estate of Catrett
USVol=477
USPage=317
Citation=106 S. Ct. 2548; 91 L. Ed. 2d 265; 1986 U.S. LEXIS 118; 54 U.S.L.W. 4775; 4 Fed. R. Serv. 3d (Callaghan) 1024
Prior=Cert. to the United States Court of Appeals for the District of Columbia Circuit
Subsequent=
Holding=A party moving for summary judgment need only show that the opposing party lacks evidence sufficient to support its case.
SCOTUS=1981-1986
Majority=Rehnquist
JoinMajority=White, Marshall, Powell, O'Connor
Concurrence=White
Dissent=Brennan
JoinDissent=Burger, Blackmun
Dissent2=Stevens
LawsApplied=Rule 56(e) of the Federal Rules of Civil Procedure

"Celotex Corp. v. Catrett", 477 U.S. 317 (1986), was a case decided by the United States Supreme Court, written by then-Associate Justice (later Chief Justice) William Rehnquist. In "Celotex", the Court held that a party moving for summary judgment need only show that the opposing party lacks evidence sufficient to support its case.

Case history

Catrett (respondent-plaintiff) sued a number of asbestos manufacturers—including Celotex (petitioner-defendant)—in United States District Court for the District of Columbia, based on evidence alleging that her husband died of health effects of asbestos exposure. The district court found that Catrett lacked evidence to show that she could prevail at trial based on a preponderance of the evidence. Under Rule 56 of the Federal Rules of Civil Procedure, summary judgment, the case was dismissed. On appeal, the Court of Appeals for the District of Columbia Circuit reversed the district court's decision. Finally, the Supreme Court reversed the appeals court's decision and remanded the case.

Issues

The issue of this case was whether petitioner-defendant Celotex Corp.'s attempted showing that the respondent-plaintiff had put forth inadequate evidence showing that her husband had been exposed to Celotex asbestos was a sufficient basis on which to grant summary judgment. Some have interpreted the decision as shifting the burden of proof for summary judgment from the movant to the respondent (facially challenging "Adickes v. S.H. Kress Co.", though the Court did not technically overrule "Kress", and in fact attempted to reconcile the "Celotex" decision with the former case). [Rowe, Thomas et al. "Civil Procedure". Foundation Press. 2004.] "Celotex" affirmed that the movant still must "show" the respondent does not have enough evidence to make out a "prima facie" case (for example, by pointing out specific discovery responses where the respondent admits a lack of evidence).

Respondent-plaintiff had argued that Celotex Corp.'s motion for summary judgment was insufficiently "supported," and that the moving party must provide affidavits. On this basis, the court of appeals reversed the decision to grant summary judgment for Celotex Corp., but the Supreme Court stated in its decision that affidavits were not necessary, as long as it demonstrated the lack of a genuine issue for trial.

Thus according to the Celotex standard there are two ways for a movant to prevail in summary judgment (supposing the respondent has no counter argument). One way is to offer evidence to negate one of the elements of the claim. The second is to show that plaintiff has no evidence to support at least one of the essential elements of the claim.

References

ee also

*List of United States Supreme Court cases, volume 477

External links

* Full text opinion from Findlaw.com