Celotex Corp. v. Catrett
From Wikipedia, the free encyclopedia
| Celotex Corp. v. Catrett | ||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|
 |
||||||||||||
| Argued April 1, 1986 Decided June 25, 1986 |
||||||||||||
|
||||||||||||
| Holding | ||||||||||||
| A party moving for summary judgment need only show that the opposing party lacks evidence sufficient to support its case. | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Jr., Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor |
||||||||||||
| Case opinions | ||||||||||||
| Majority by: Rehnquist Joined by: White, Marshall, Powell, O'Connor Concurrence by: White Dissent by: Brennan Joined by: Burger, Blackmun Dissent by: Stevens |
||||||||||||
| Laws applied | ||||||||||||
| 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.
Contents |
[edit] 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.
[edit] 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).[1] 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 the claim.
[edit] References
- ^ Rowe, Thomas et al. Civil Procedure. Foundation Press. 2004.
[edit] See also
[edit] External links
- Full text opinion from Findlaw.com
