Celotex Corp. v. Catrett
477 U.S. 317, 106 S. Ct. 2548, 91 L. Ed. 2d 265 (1986)
Mr. Catrett died, possibly due
to exposure to asbestos. Catrett's wife sued Celotex (and 14 other
asbestos manufacturers) for negligence, breach of warrantee, and strict
Celotex filed a motion for summary
Celotex argued that Catrett
had not produced any evidence that any Celotex product in particular
caused Mr. Catrett's death. Even if Catrett could show that Mr. Catrett
died from asbestos exposure, that doesn't prove that he died from
exposure to Catrett's asbestos.
In technical terms, Celotex
was arguing that they weren't the "proximate cause" of Mr.
Note that in tort law, in
order to show liability Catrett had to prove duty, breach of duty, harm,
proximate cause, and failure to use due care. If any element fails, the
case fails. So Celotex could win on summary judgment if they could show there was no evidence of
any single element.
Basically, if Catrett
couldn't make at least some argument that there was proximate cause,
then they can't possibly win the case, so there is no point in
The Trial Court granted summary
judgment to Celotex and dismissed the
case. Catrett appealed.
The Appellate Court reversed
the motion for summary judgment.
The Appellate Court found
that Celotex's motion was rendered "fatally defective" by the
fact that they had not produced any evidence, in the form of affidavits
or otherwise, to support their argument.
Rule 56(e) establishes that the party opposing the
motion for summary judgment (Catrett) bears the burden of
responding only after the moving party (Celotex) has met it's burden of
coming forward with proof of the absence of any genuine issues of
So basically, the Court
was saying that in order to get summary judgment, Celotex would have to show evidence that
their products didn't
cause Mr. Catrett's death.
The US Supreme Court reversed
the Appellate Court and remanded the case to see if summary judgment was warranted based on the evidence.
The US Supreme Court found
that the Appellate Court's decision was inconsistent with Rule 56(c).
The Court felt that the
Appellate Court had erred when they found that Celotex had to have proof
negating Catrett's claim. All Rule 56(c) required Celotex to do in order to qualify for summary
judgment was suggest to the Court that Catrett had presented
no proof supporting her claim.
The Court found that the
Appellate Court should have looked at Catrett's evidence to see if it could
demonstrate that there was a "genuine material issue of fact."
The Court pointed out that
Trial Courts have the ability to grant summary judgment without even being asked by either party (aka sua
sponte). Therefore, it wouldn't make
sense to hold that a party moving for summary judgment must be required to show proof to support
After the Supreme Court's
decision, the case went back to the Appellate Court who looked at the
evidence and found that Catrett's evidence (in particular a letter from
Mr. Catrett's employer) established a genuine issue of material fact, and
therefore summary judgment was not
Basically, this case said that
under Rule 56(c) a defendant could
file a motion for summary judgment that simply said, "I
don't believe the plaintiff can prove their case." If the plaintiff
fails present evidence in support of their claim, the judge can dismiss
You don't have to affirmatively
prove your position to get summary judgment, you only have to say that the other side doesn't have enough
evidence to bother having a trial. If the judge agrees with you, the
case is dismissed.