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Celotex Corp. v. Catrett | 477 U.S. 317 (1986)
Rule 56 of the Federal Rules of Civil Procedure governs the entry of summary judgment in federal court. Prior to the 2010 amendment, Rule 56(c) provided that a court may grant summary judgment as a matter of law if the pleadings, depositions, interrogatories, and affidavits demonstrate that there’s no genuine issue of material fact.
In Celotex Corporation versus Catrett, Myrtle Catrett brought a wrongful death action on behalf of her husband against Celotex and over a dozen other asbestos manufacturers in federal court in Washington, D.C. Myrtle claimed exposure to these manufacturers’ asbestos caused her husband to die from an asbestos-related illness.
Celotex moved for summary judgment, arguing that Catrett hadn’t produced any evidence linking Celotex products to the death of Catrett’s husband. However, when making its motion, Celotex didn’t provide any evidence to show its products had not caused the death either.
In opposition to Celotex’s motion, Catrett submitted three documents that she claimed showed a material factual dispute about whether exposure to Celotex’s products had caused her husband’s death. Celotex objected that the documents were inadmissible hearsay and couldn’t be considered.
The district court granted Celotex’s motion for summary judgment, even though Celotex hadn’t provided affidavits or other evidence to support its motion, because it concluded that Catrett hadn’t met her burden of showing that her husband had been exposed to Celotex’s product.
On appeal, the parties disputed what the burden of proof was, and on whom it rested, on a motion for summary judgment under Rule 56. Celotex argued that to defeat a summary judgment motion, the burden should be on Catrett as the nonmoving party. Celotex argued that Catrett must show, based on some affirmative evidence, such as affidavits, that there was a genuine issue of material fact for trial. Catrett argued that summary judgment was improper, because Celotex didn’t “support” its motion with affirmative evidence.
The appellate court ruled in Catrett’s favor, holding that, in a Rule 56 motion for summary judgement, the burden is on the moving party to prove an absence of any genuine issue of material fact by affirmative evidence. Celotex petitioned the United States Supreme Court for certiorari.
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