Summary
The Supreme Court held that summary judgment may be entered against a party who fails to make a sufficient showing on an essential element of its case for which it bears the burden of proof at trial. The moving party need not always support its motion with affidavits or other materials affirmatively negating the opponent's claim; it may point out the absence of evidence supporting that claim. The Court reversed and remanded for consideration of whether the plaintiff's opposition established sufficient, admissible evidence of exposure to Celotex products.
Topics
Practice areas
Questions Presented
- Whether a party moving for summary judgment must support the motion with affidavits or other evidence affirmatively negating the opposing party's claim.
- Whether summary judgment is proper when the nonmoving party fails, after adequate discovery, to make a sufficient showing establishing an essential element on which that party bears the burden of proof at trial.
- Whether the materials submitted by Catrett established exposure to Celotex products and, if reduced to admissible evidence, would be sufficient to carry her trial burden.
Holdings
- Federal Rule of Civil Procedure 56 does not require the moving party to support its motion with affidavits or other materials affirmatively negating the opponent's claim. A movant may discharge its initial responsibility by identifying the absence of evidence supporting an essential element of the nonmoving party's case.
- After adequate time for discovery, summary judgment must be entered against a party that fails to make a sufficient showing establishing the existence of an element essential to that party's case and on which that party bears the burden of proof at trial.
- When the motion properly demonstrates an absence of evidence supporting an essential element, the nonmoving party must go beyond the pleadings and designate specific facts, using the evidentiary materials identified in Rule 56, showing that there is a genuine issue for trial.
- The case must be remanded for the Court of Appeals for the District of Columbia Circuit to determine in the first instance whether Catrett made an adequate showing of exposure and whether that showing, if reduced to admissible evidence, would satisfy her trial burden.
Key quotations
“In our view, the plain language of Rule 56(c) mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party's case, and on which that party will bear the burden of proof at trial.” (477 U.S. at 322-323)
“But unlike the Court of Appeals, we find no express or implied requirement in Rule 56 that the moving party support its motion with affidavits or other similar materials negating the opponent's claim.” (477 U.S. at 323)
“Rule 56(e) therefore requires the nonmoving party to go beyond the pleadings and by her own affidavits, or by the “depositions, answers to interrogatories, and admissions on file,” designate “specific facts showing that there is a genuine issue for trial.”” (477 U.S. at 324)
“Summary judgment procedure is properly regarded not as a disfavored procedural shortcut, but rather as an integral part of the Federal Rules as a whole.” (477 U.S. at 327)
Factual background
Myrtle Nell Catrett alleged that her husband's death in 1979 resulted from exposure to asbestos products manufactured or distributed by fifteen corporations, including Celotex. After discovery, Celotex moved for summary judgment on the ground that Catrett had failed to produce evidence identifying exposure to Celotex products. Catrett responded with a deposition transcript and letters tending to show exposure to Celotex-related asbestos products in Chicago during 1970 and 1971, but Celotex argued that the materials were inadmissible hearsay.
Procedural history
Catrett filed a wrongful-death action in the United States District Court for the District of Columbia alleging that her husband's death resulted from exposure to asbestos products manufactured or distributed by several defendants. The district court granted Celotex summary judgment because Catrett had made no showing that the decedent was exposed to Celotex's products. The District of Columbia Circuit reversed, holding that Celotex's motion was defective because it was not supported by evidence negating exposure. The Supreme Court reversed and remanded for the court of appeals to determine whether Catrett's opposition established exposure and whether admissible evidence would suffice to carry her trial burden.
Remand instructions
The Court of Appeals for the District of Columbia Circuit was directed to determine whether Catrett made an adequate showing of exposure to Celotex's products and whether that showing, if reduced to admissible evidence, would be sufficient to carry her burden of proof at trial.