Caseflicks

Supreme Court of the United States • 1986

Celotex Corp. v. Catrett, Administratrix of the Estate of Catrett

477 U.S. 317 | 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 1024

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Takeaway

In short, Celotex holds that a summary-judgment movant need not disprove the opponent's case; after adequate discovery, it may prevail by showing that the party with the trial burden lacks evidence on an essential element.

Background

Myrtle Catrett, as administratrix of her husband's estate, brought a wrongful-death action alleging that Louis Catrett died from exposure to asbestos products manufactured or distributed by Celotex and other companies. Her claims included negligence, breach of warranty, and strict liability. Because exposure to a Celotex product was essential to liability, she would bear the burden of proving that element at trial.

After discovery had begun, Celotex moved for summary judgment. It pointed to Catrett's interrogatory answers and asserted that she had identified no witness or other evidence showing that her husband had been exposed to a Celotex product. Catrett responded with three documents tending to show exposure in Chicago, including a former supervisor's letter and a prior deposition, but Celotex argued that the materials were hearsay.

The District Court granted summary judgment, stating that there was no showing of exposure to Celotex products in the District of Columbia or elsewhere within the relevant period. The D.C. Circuit reversed. It held that Celotex's motion was defective because Celotex had not submitted affidavits or other affirmative evidence disproving exposure. The Supreme Court granted review to resolve disagreement over what a summary-judgment movant must show when the opposing party bears the burden of proof at trial.

Issues

Issue #1

Whether a defendant seeking summary judgment must submit affirmative evidence negating an essential element of the plaintiff's claim when the plaintiff bears the burden of proof on that element at trial.

Holding

No. After adequate time for discovery, a defendant may obtain summary judgment by pointing out that the record lacks evidence sufficient to establish an essential element on which the plaintiff bears the burden of proof at trial.

Reasoning

Rule 56(c) authorizes summary judgment when the record shows no genuine dispute of material fact and the movant is entitled to judgment as a matter of law. A complete failure of proof on an element essential to the nonmovant's case means there can be no genuine dispute over a material fact, because the other factual disputes no longer matter.

The summary-judgment standard mirrors the directed-verdict standard. If the evidence would not permit a reasonable jury to find for the party that bears the burden of proof on an essential element, trial is unnecessary and judgment may be entered before trial.

The moving party still has an initial responsibility: it must tell the district court the basis for its motion and identify the record materials showing the absence of a genuine factual issue. But Rule 56 does not require the movant to produce affidavits or similar evidence affirmatively disproving the opponent's claim.

Rules 56(a) and 56(b) expressly permit parties to move for summary judgment with or without supporting affidavits, and Rule 56(c)'s reference to affidavits 'if any' confirms that affidavits are not invariably required. A movant may therefore discharge its burden by showing, including by pointing to the record, that the nonmovant lacks evidence supporting its case.

Once a properly supported motion identifies the absence of proof on an essential element, Rule 56(e) requires the nonmoving party to go beyond the pleadings and designate specific facts showing a genuine issue for trial. The nonmovant may use depositions, interrogatory answers, admissions, affidavits, and other Rule 56 materials; she need not present evidence in a form that is itself admissible at trial.

Issue #2

Whether Adickes v. S.H. Kress & Co. required Celotex to offer affirmative evidence disproving Catrett's claimed asbestos exposure before Catrett had to respond with evidence.

Holding

No. Adickes did not impose a universal requirement that a movant negate the opponent's claim with affirmative evidence, particularly where the opponent bears the burden of proof at trial.

Reasoning

Adickes correctly recognized that the movant bears an initial burden under Rule 56. But its statement that the movant must initially show the absence of a genuine issue should not be read to require affirmative evidence negating every element of the nonmovant's claim.

Where the nonmovant bears the ultimate trial burden on a dispositive issue, the movant can make the required showing by identifying the absence of evidence supporting that issue. Reading Adickes otherwise would improperly turn the 1963 amendment to Rule 56(e), which was meant to prevent reliance on bare pleadings, into a rule making summary judgment more difficult to obtain.

The Court also noted that district courts may sometimes grant summary judgment sua sponte when the losing party has notice and an opportunity to present evidence. It would make little sense to allow a court to enter judgment on its own initiative but forbid the same result merely because the defendant formally requested it.

Issue #3

Whether Catrett was deprived of a fair opportunity to develop evidence because Celotex moved for summary judgment too early.

Holding

No. The motion was not premature on this record, and Rule 56(f) provided the appropriate protection against genuinely premature summary-judgment motions.

Reasoning

Celotex moved for summary judgment approximately one year after the action began, and the parties had conducted discovery. The Court therefore found no serious basis to say that Catrett had been railroaded by a motion filed before she had a fair chance to obtain supporting evidence.

If a nonmoving party genuinely cannot yet present facts essential to oppose summary judgment, Rule 56(f) permits the court to deny the motion, continue the hearing, or allow further discovery. That mechanism protects parties from premature motions without creating a categorical requirement that movants submit affirmative negating evidence.

Issue #4

Whether Catrett's submitted materials adequately established a genuine issue concerning exposure to Celotex products and whether that proof could satisfy her burden at trial.

Holding

The Supreme Court did not decide those questions and remanded for the Court of Appeals to address them in the first instance.

Reasoning

The Court of Appeals had reversed solely because it believed Celotex's motion was procedurally defective. It had not determined whether Catrett's documents actually made a sufficient showing of exposure or whether the evidence, if reduced to admissible form, could support a verdict under the governing law.

The Court concluded that the Court of Appeals was better positioned to resolve those issues on remand, including any questions involving applicable local law. The Supreme Court therefore reversed the D.C. Circuit's legal rule and returned the case for further proceedings.

Concurrences

Justice White

Reasoning

Justice White agreed that a defendant need not always submit affidavits or affirmative evidence disproving the plaintiff's case. A movant may rely on depositions, interrogatory answers, and similar record materials to demonstrate that the plaintiff lacks proof and that no factual dispute exists.

He emphasized, however, that a movant must actually carry Rule 56's initial burden. A conclusory assertion that the plaintiff has no evidence, unsupported by any effort to identify record materials establishing that point, is insufficient.

Justice White also stressed that a plaintiff has no general duty to initiate discovery, depose her own witnesses, or secure affidavits merely to guard against a bare no-evidence motion. If the plaintiff has identified a witness supporting her claim, summary judgment should not be granted unless the defendant somehow shows that the witness's possible testimony would not create a genuine issue.

Because the Court of Appeals had not considered whether Catrett sufficiently disclosed supporting evidence, including her proposed witness, Justice White joined the remand for that question to be resolved below.

Dissents

Justice Brennan

Reasoning

Justice Brennan agreed that Rule 56 does not invariably require a defendant to submit affirmative evidence disproving the plaintiff's claim. But he believed the majority had not adequately explained what a no-evidence movant must do to satisfy its own initial burden of production, an issue of recurring importance in trial courts.

In his view, Rule 56 imposes an initial burden of production and an ultimate burden of persuasion on the movant. When the nonmovant bears the trial burden, the movant may either submit affirmative evidence negating an essential element or affirmatively demonstrate that the record evidence is insufficient to establish that element. A conclusory claim that the opponent has no evidence does not suffice.

A defendant choosing the second route must address the actual record. If the record contains evidence or identifies a witness supporting the nonmovant's claim, the movant must explain why that material is inadequate before the burden shifts to the nonmovant to produce more evidence or seek additional discovery.

Celotex failed that standard because it knew that Catrett had provided documents suggesting exposure and had identified Mr. Hoff as a possible supporting witness. Yet its renewed motion asserted that the record was totally devoid of evidence without attacking the adequacy of those materials. Justice Brennan considered the case materially indistinguishable from Adickes and would have affirmed the D.C. Circuit's reversal of summary judgment.

Justice Stevens

Reasoning

Justice Stevens would have affirmed on a narrower ground. He read Celotex's motion and argument as claiming only that Catrett had failed to show exposure to Celotex products within the District of Columbia.

Catrett had produced materials tending to show that her husband was exposed to a Celotex product in Chicago. Even if those materials were not yet in admissible form, they were enough under Rule 56 to defeat a motion premised on the absence of District of Columbia exposure.

In Justice Stevens's view, the District Court's later reference to no exposure 'in the District of Columbia or elsewhere' did not transform the motion into the broader no-evidence question the Supreme Court decided. Because the District Court's ruling was plainly erroneous on the ground actually argued, he saw no need for an abstract reconstruction of Rule 56 or a remand.