Myrtle Catrett sued Celotex and other corporations, alleging that her husband's death resulted from exposure to asbestos-containing products they manufactured or distributed. After discovery, Celotex moved for summary judgment, arguing that Catrett had failed to produce evidence that the decedent had been exposed to Celotex products. In response, Catrett produced three documents suggesting exposure in Chicago, but Celotex argued they were hearsay. The district court granted summary judgment for Celotex, and the D.C. Circuit reversed on the ground that Celotex had not supported its motion with evidence negating exposure.
Must a party moving for summary judgment under Federal Rule of Civil Procedure 56 produce affirmative evidence negating the nonmoving party’s claim, or may it prevail by showing that the nonmoving party lacks evidence on an essential element for which that party bears the burden of proof at trial?
Under Rule 56, summary judgment is proper after adequate time for discovery when the nonmoving party fails to make a showing sufficient to establish an essential element of its case on which it bears the burden of proof at trial. The moving party need not support its motion with affidavits or other materials negating the opponent’s claim; it may discharge its initial burden by pointing out the absence of evidence supporting the nonmovant’s case.
No. A summary-judgment movant does not have to produce evidence disproving the opponent’s claim when the opponent bears the burden of proof on that issue at trial. Celotex satisfied its Rule 56 burden by identifying the absence of evidence of exposure, so the court of appeals erred in requiring affirmative negating evidence.
The Court read Rule 56(c), together with Rules 56(a), (b), and (e), to permit summary judgment "with or without supporting affidavits" so long as the materials before the court show no genuine issue of material fact. Where the nonmoving party bears the burden of proof at trial, a complete failure of proof on an essential element makes all other facts immaterial. The Court rejected the D.C. Circuit’s reading of Adickes v. S. H. Kress & Co., explaining that a movant may satisfy its initial burden by pointing out an absence of evidence rather than producing evidence negating the claim. Because the court of appeals had not addressed the sufficiency of Catrett’s showing, the Supreme Court remanded for that determination.
Justice Brennan, joined by Justice Blackmun, agreed that a movant need not always produce affidavits negating the claim but argued the movant must at least demonstrate, by reference to the record, the absence of a genuine factual issue; he believed Celotex had not adequately done so. Justice Stevens separately dissented, contending the Court should affirm on the narrower ground that Catrett had made an adequate showing of exposure outside the District of Columbia.
Celotex is a foundational summary-judgment case and one of the Supreme Court’s 1986 "summary judgment trilogy." It clarified that a defendant may obtain summary judgment by showing the plaintiff lacks evidence on an essential element, rather than by affirmatively disproving the claim. It is closely associated with Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986), which defined the genuine-issue standard, and Matsushita Electric Industrial Co. v. Zenith Radio Corp., 475 U.S. 574 (1986), which emphasized that implausible claims require more persuasive evidentiary support. Together, these cases strengthened summary judgment as a principal device for disposing of factually unsupported claims.
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) |
Verified |
Matsushita Electric Industrial Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) |
Verified |
Enter a case name or citation — get a structured brief where every case it cites is checked against real law.
Try Law Student Workbench →