Celotex Corp. v. Catrett, 477 U.S. 317 (1986)

Abestos on the job site.

FACTS: Myrtle Catrett alleged her husband’s exposure to Celotex Corporation’s asbestos products resulted in his death.

PROCEDURAL HISTORY: Catrett (Respondent) sued Celotex (Petitioner) for strict liability, negligence, and breach of warranty. The district court granted Petitioner’s summary judgment motion. Respondent appealed. The appeals court reversed the decision of the district court. Petitioner filed certiorari. SCOTUS granted the petition to resolve the conflict.

JUDGMENT: Reversed and remanded.

ISSUE: Whether the Petitioner sufficiently demonstrated the Respondent lacked evidence to establish elements of their case at trial.

HOLDING OF THE COURT: A party cannot move for summary judgment with a conclusory assertion that plaintiffs have no evidence to prove their case.

RATIONALE: The standard for granting summary judgment is similar to the directed verdict standard. Fed. R. Civ. P. 50(a). In SCOTUS’ view, lower courts must construe Rule 56 with due regard of individual asserting the claims and defenses that will eventually be tried by a jury. The rule must also be construed with due regard for the individual in opposition that those claims and defenses have no factual basis.

CONCURRENCE: (White, J., concurring) A plaintiff does not have to initiate any discovery or reveal their witnesses or evidence unless the court orders or they are required to do so by discovery rules. According to Justice White, it is the defendant who must negate a plaintiff’s basis for the suit.

DISSENT: (Brennan, J.; The Chief Justice; Blackmun, J., dissenting) The Dissenters felt the Court did not explain what the requirement is for the party who claims a non-moving party cannot prove their case, and then moves for summary judgment. Be that it may, the Dissenters felt Celotex failed to both, provide affirmative evidence and attack the Respondent’s evidence. Because Celotex failed to discharge its burden of production under Rule 56, the district court erred when it granted summary judgment.

Quianna Canada

Quianna Canada

Quianna Canada is a B.A. Law student at the University of Arizona, a Human Rights Defender, anti-torture activist. Her conversance with the American criminal justice system has made her passionate about justice and equality. Her focused researched on the ills of rankism, racism, and gender-based prejudice makes her an insightful expert at identifying maltreatment immanent in institutions, and how oppression effects ostracised persons in the world.

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