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 liability.
  • Celotex filed a motion for summary judgment.
    • 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. Catrett’s death.
    • 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 proceeding.
  • The Trial Court granted summary judgment to Celotex and dismissed the case. Catrett appealed.
  • The Appellate Court reversed the motion for summary judgment. Celotex appealed.
    • 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 material fact.
        • 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 their claim.
  • 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 warranted.
  • 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 the case.
    • 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.