Brill v. Guardian Life Insurance Co

In Brill v. Guardian Life Ins. Co. of Am., 142 N.J. 520, 540, 666 A.2d 146 (1995), the Supreme Court said that in deciding a motion for summary judgment, the motion judge must "consider whether the competent evidential materials presented, when viewed in the light most favorable to the non-moving party . . ., are sufficient to permit a rational factfinder to resolve the alleged disputed issue in favor of the non-moving party." Brill, supra, at 523, 666 A.2d 146. Only where the party opposing the motion has presented evidence that creates a "genuine issue as to any material fact challenged" should a court deny a summary judgment motion. Id. at 529, 666 A.2d 146. When "the evidence is so one-sided that one party must prevail as a matter of law . . . the trial court should not hesitate to grant summary judgment." Id. at 540, 666 A.2d 146. The New Jersey Supreme Court held that a trial court must look to whether the evidence presents a sufficient disagreement as to a material fact to require submission to a jury. Further, "when the evidence is so one-sided that one party must prevail as a matter of law . . . the trial court should not hesitate to grant summary judgment." Id.