Celotex Corp. v. Catrett, 477 U.S. 317 (1986), is a landmark United States Supreme Court decision that profoundly shaped the application and interpretation of summary judgment under Federal Rule of Civil Procedure 56. It is regarded as one of the most significant cases in federal civil procedure and is a key part of what is commonly referred to as the “summary judgment trilogy,” alongside Anderson v. Liberty Lobby, Inc. and Matsushita Electric Industrial Co. v. Zenith Radio Corp.
The decision clarified the burden of proof for parties moving for summary judgment and established a clear procedure for courts to follow when considering whether a case should proceed to trial.
Facts of Celotex Corp. v. Catrett Case
In Celotex Corp. v. Catrett, the respondent, Mrs. Catrett, brought an action in the United States District Court for the District of Columbia against 15 named companies, including the petitioner, Celotex Corporation.
The basis of her lawsuit was that her husband, Louis H. Catrett, had died in 1979 allegedly due to health problems resulting from exposure to asbestos-containing products manufactured or distributed by the defendants. The causes of action included negligence, breach of warranty, and strict liability.
Two of the defendants succeeded in having the claims against them dismissed for lack of personal jurisdiction. The remaining 13 defendants, including Celotex, moved for summary judgment on other grounds.
Celotex filed its motion for summary judgment in September 1981. In its motion, Celotex asserted that summary judgment was proper because Mrs. Catrett had failed to produce evidence that any of Celotex’s products were the proximate cause of her husband’s injuries or death within the jurisdictional reach of the court.
Specifically, Celotex pointed out that Mrs. Catrett had failed to identify any witnesses who could testify to her husband’s exposure to Celotex products during discovery.
In response to the summary judgment motion, Mrs. Catrett submitted three documents: a transcript of a deposition of her late husband, a letter from one of her husband’s former employers (whom petitioner planned to call as a trial witness), and a letter from an official of an insurance company to Mrs. Catrett’s attorney. Mrs. Catrett claimed these documents tended to establish that the decedent had been exposed to Celotex’s asbestos products in Chicago in 1970–1971.
Celotex objected to these documents on the grounds that they were hearsay and therefore inadmissible as evidence. The district court sustained Celotex’s objection and found that Mrs. Catrett lacked admissible evidence to show that she could prevail at trial by a preponderance of the evidence.
Relying on Rule 56 of the Federal Rules of Civil Procedure, the district court granted summary judgment in favor of Celotex and dismissed the case.
Procedural History
After the district court entered summary judgment for Celotex, Mrs. Catrett appealed to the United States Court of Appeals for the District of Columbia Circuit. The Court of Appeals reversed the district court’s decision.
The appellate court held that Celotex had not sufficiently supported its motion for summary judgment and that affidavits or other supporting materials were required to demonstrate the absence of a genuine issue of material fact. Dissatisfied with this ruling, Celotex petitioned for certiorari, which was granted by the Supreme Court.
Issue Presented
The core issue in Celotex Corp. v. Catrett was:
Is it sufficient for a party moving for summary judgment to show that the opposing party lacks evidence necessary to support its case, or must the moving party provide affirmative evidence negating the opponent’s claim?
Celotex Corp. v. Catrett Judgment
The United States Supreme Court, in Celotex Corp. v. Catrett, held that a party seeking summary judgment does not need to provide affidavits or other evidence to negate the nonmovant’s claim. Instead, it is enough for the moving party to show—by pointing to a lack of evidence—that the nonmoving party has failed to establish an essential element of their case for which they bear the burden of proof at trial.
The decision of the Court of Appeals was reversed and the case was remanded.
Reasoning of the Court
Justice Rehnquist, writing for the majority in Celotex Corp. v. Catrett, explained that summary judgment serves as a procedural device to avoid unnecessary trials where there is no genuine issue as to any material fact. According to Rule 56(c), summary judgment must be entered when, after adequate discovery, the nonmoving party fails to make a sufficient showing of an essential element for which it has the burden of proof.
The Court noted that there is no express or implied requirement in Rule 56 that the moving party must provide affidavits or evidence negating the opponent’s claim. Rather, the moving party can point out the absence of evidence supporting the nonmovant’s claim. Once the moving party does this, the burden shifts to the nonmoving party to produce evidence demonstrating a genuine issue for trial.
The Supreme Court in Celotex Corp. v. Catrett clarified that a proper summary judgment motion may be made “with or without supporting affidavits.” The Court also reconciled its decision with the earlier case of Adickes v. S.H. Kress & Co. by stating that the movant must “show” the absence of evidence, but does not need to submit evidence to negate the opponent’s claims.
Concurrence
Justice Byron White wrote a concurring opinion in Celotex Corp. v. Catrett, emphasizing that it is not enough for the moving party to simply assert that the plaintiff has no evidence. Some minimal support, such as discovery responses showing a lack of evidence, must be presented.
Conclusion
Celotex Corp. v. Catrett is a foundational Supreme Court case that modernized and clarified the standard for summary judgment in federal civil litigation. The decision promotes judicial efficiency and ensures that only cases supported by sufficient evidence reach trial. The clarity provided by Celotex Corp. v. Catrett continues to guide courts, attorneys, and litigants in civil proceedings across the United States.