''Celotex Corp. v. Catrett'', 477 U.S. 317 (1986), was a case decided by the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...

. Written by

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William Rehnquist William Hubbs Rehnquist (October 1, 1924 – September 3, 2005) was an American attorney who served as the 16th chief justice of the United States from 1986 until his death in 2005, having previously been an associate justice from 1972 to 1986. ...

, the decision of the Court held that a party moving for

summary judgment In law, a summary judgment, also referred to as judgment as a matter of law or summary disposition, is a Judgment (law), judgment entered by a court for one party and against another party summarily, i.e., without a full Trial (law), trial. Summa ...

need show only that the opposing party lacks evidence sufficient to support its case. A broader version of that doctrine was later formally added to the

Federal Rules of Civil Procedure The Federal Rules of Civil Procedure (officially abbreviated Fed. R. Civ. P.; colloquially FRCP) govern civil procedure in United States district courts. They are the companion to the Federal Rules of Criminal Procedure. Rules promulgated by the ...

. ''Celotex'' was one of a "trilogy" of U.S. Supreme Court decisions on summary judgment issued in 1986, the other two being '' Anderson v. Liberty Lobby'' and '' Matsushita Electric Industrial Co. v. Zenith Radio Corp.''. Within 20 years these three became the most-cited Supreme Court decisions in the U.S. federal court system.

Case history

In September 1980, Catrett (respondent-plaintiff) sued fifteen

asbestos Asbestos ( ) is a group of naturally occurring, Toxicity, toxic, carcinogenic and fibrous silicate minerals. There are six types, all of which are composed of long and thin fibrous Crystal habit, crystals, each fibre (particulate with length su ...

manufacturers Manufacturing is the creation or production of goods with the help of equipment, labor, machines, tools, and chemical or biological processing or formulation. It is the essence of the secondary sector of the economy. The term may refer to a r ...

and distributors—including Celotex (petitioner-defendant)—in

United States District Court for the District of Columbia The United States District Court for the District of Columbia (in case citations, D.D.C.) is a United States district court, federal district court in Washington, D.C. Along with the United States District Court for the District of Hawaii and ...

, on the basis of evidence alleging that her husband, Louis H. Catrett, died in 1979 of health effects of exposure to

manufactured or distributed by the defendants. Catrett sought recovery for claims arising from

negligence Negligence ( Lat. ''negligentia'') is a failure to exercise appropriate care expected to be exercised in similar circumstances. Within the scope of tort law, negligence pertains to harm caused by the violation of a duty of care through a neg ...

, breach of warranty, and

strict liability In criminal and civil law, strict liability is a standard of liability under which a person is legally responsible for the consequences flowing from an activity even in the absence of fault or criminal intent on the part of the defendant. Und ...

on the part of the defendant

corporations A corporation or body corporate is an individual or a group of people, such as an association or company, that has been authorized by the State (polity), state to act as a single entity (a legal entity recognized by private and public law as ...

. Two of the defendants filed motions for dismissal for lack of personal jurisdiction. The district court granted the motions and the remaining thirteen defendant corporations including Celotex filed motions for summary judgment on other grounds. Celotex filed its motion in September 1981 and argued that summary judgment was proper because Catrett had failed to produce evidence that any of Celotex's products were the proximate cause of damages within the jurisdictional limits of the court. Celotex noted that in interrogatories, Catrett had failed to identify any witnesses who could testify to her husband's exposure to Celotex's products. Catrett then sought to enter into evidence three documents: a transcript of a deposition of decedent, a letter from one of decedent's former employers whom petitioner planned to call as a trial witness, and a letter from an official of an insurance company to Catrett's attorney. Catrett alleged that each of the documents tended to establish that the decedent had been exposed to Celotex's asbestos products in

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during 1970–1971. Celotex objected to the evidence, arguing that the three documents were

hearsay Hearsay, in a legal forum, is an out-of-court statement which is being offered in court for the truth of what was asserted. In most courts, hearsay evidence is Inadmissible evidence, inadmissible (the "hearsay evidence rule") unless an exception ...

and therefore could not be considered in opposition to Celotex's motion for summary judgment. The district court sustained Celotex's objection to the evidence. The federal district court found that Catrett lacked evidence to show that she could prevail at trial on the basis of a preponderance of the evidence. Under Rule 56 of the

, 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.

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 moving party ("movant") to the respondent (facially challenging '' Adickes v. S.H. Kress Co.'' (1970), though the Court did not technically overrule ''Kress'', and in fact attempted to reconcile the ''Celotex'' decision with the former case). ''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, the movant in a motion for summary judgment must show the absence of genuine factual issues in the nonmovant's case, although the movant is not required specifically to negate any aspects of his opponent's claims.''Celotex Corp. v. Catrett'', 477 U.S. 317, 323 (1986)

References

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