Celotex Corp. v. Catrett
Encyclopedia
Celotex Corp. v. Catrett, 477 U.S. 317 (1986), was a case decided by the United States Supreme Court
, written by then-Associate Justice
(later Chief Justice
) William Rehnquist
. In Celotex, the Court held that a party moving for summary judgment
need only show that the opposing party lacks evidence sufficient to support its case.
manufacturers and distributors—including Celotex (petitioner-defendant)—in United States District Court for the District of Columbia
, on the basis of evidence alleging that her husband, Louis H. Catrett, died in 1979 of health effects of exposure to asbestos
manufactured or distributed by the defendants. Catrett sought recovery for claims arising from negligence
, breach of warranty, and strict liability
on the part of the defendant corporations.
Two of the defendants filed motions for dismissal for lack of in personam 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. Cartrett 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 Cartrett's attorney. Cartrett alleged that each of the documents tended to establish that the decedent had been exposed to Celotex's asbestos products in Chicago
during 1970-1971. Celotex objected to the evidence, arguing that the three documents were hearsay
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 Federal Rules of Civil Procedure
, summary judgment
, 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.
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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
, written by then-Associate Justice
Associate Justice
Associate Justice or Associate Judge is the title for a member of a judicial panel who is not the Chief Justice in some jurisdictions. The title "Associate Justice" is used for members of the United States Supreme Court and some state supreme courts, and for some other courts in Commonwealth...
(later Chief Justice
Chief Justice
The Chief Justice in many countries is the name for the presiding member of a Supreme Court in Commonwealth or other countries with an Anglo-Saxon justice system based on English common law, such as the Supreme Court of Canada, the Constitutional Court of South Africa, the Court of Final Appeal of...
) William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
. In Celotex, the Court held that a party moving for summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
need only show that the opposing party lacks evidence sufficient to support its case.
Case history
In September 1980, Catrett (respondent-plaintiff) sued fifteen asbestosAsbestos
Asbestos is a set of six naturally occurring silicate minerals used commercially for their desirable physical properties. They all have in common their eponymous, asbestiform habit: long, thin fibrous crystals...
manufacturers and distributors—including Celotex (petitioner-defendant)—in United States District Court for the District of Columbia
United States District Court for the District of Columbia
The United States District Court for the District of Columbia is a federal district court. Appeals from the District are taken to the United States Court of Appeals for the District of Columbia Circuit The United States District Court for the District of Columbia (in case citations, D.D.C.) is a...
, on the basis of evidence alleging that her husband, Louis H. Catrett, died in 1979 of health effects of exposure to asbestos
Asbestos
Asbestos is a set of six naturally occurring silicate minerals used commercially for their desirable physical properties. They all have in common their eponymous, asbestiform habit: long, thin fibrous crystals...
manufactured or distributed by the defendants. Catrett sought recovery for claims arising from negligence
Negligence
Negligence is a failure to exercise the care that a reasonably prudent person would exercise in like circumstances. The area of tort law known as negligence involves harm caused by carelessness, not intentional harm.According to Jay M...
, breach of warranty, and strict liability
Strict liability
In law, strict liability is a standard for liability which may exist in either a criminal or civil context. A rule specifying strict liability makes a person legally responsible for the damage and loss caused by his or her acts and omissions regardless of culpability...
on the part of the defendant corporations.
Two of the defendants filed motions for dismissal for lack of in personam 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. Cartrett 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 Cartrett's attorney. Cartrett alleged that each of the documents tended to establish that the decedent had been exposed to Celotex's asbestos products in Chicago
Chicago
Chicago is the largest city in the US state of Illinois. With nearly 2.7 million residents, it is the most populous city in the Midwestern United States and the third most populous in the US, after New York City and Los Angeles...
during 1970-1971. Celotex objected to the evidence, arguing that the three documents were hearsay
Hearsay
Hearsay is information gathered by one person from another person concerning some event, condition, or thing of which the first person had no direct experience. When submitted as evidence, such statements are called hearsay evidence. As a legal term, "hearsay" can also have the narrower meaning of...
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 Federal Rules of Civil Procedure
Federal Rules of Civil Procedure
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. The FRCP are promulgated by the United States Supreme Court pursuant to the Rules Enabling Act, and then the United States Congress has 7 months to veto the rules promulgated or they become part of the...
, summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
, the case was dismissed. On appeal, the Court of Appeals for the District of Columbia Circuit
United States Court of Appeals for the District of Columbia Circuit
The United States Court of Appeals for the District of Columbia Circuit known informally as the D.C. Circuit, is the federal appellate court for the U.S. District Court for the District of Columbia. Appeals from the D.C. Circuit, as with all the U.S. Courts of Appeals, are heard on a...
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., 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.
See also
- List of United States Supreme Court cases, volume 477
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court