Celotex Corp. v. Catrett

In Celotex Corp. v. Catrett, 477 U.S. 317 (1986), the plaintiff ("Catrett") sued 15 corporations (including Celotex Corporation, hereinafter "Celotex") for wrongful death on behalf of her late husband. Id. at 319, 106 S. Ct. at 2550. Catrett alleged her husband's death resulted from his "exposure to products containing asbestos manufactured or distributed by" Celotex. Id. at 319, 106 S. Ct. at 2551. Celotex moved for summary judgment because Catrett had "failed to produce evidence that any Celotex product . . . was the proximate cause of the injuries alleged." Id. "In particular, petitioner noted that respondent had failed to identify, in answering interrogatories specifically requesting such information, any witnesses who could testify about the decedent's exposure to petitioner's asbestos products." Id. at 320, 106 S. Ct. at 2551. Catrett then produced a deposition transcript from her deceased husband, a letter from one of her husband's previous employers and a letter from an insurance company; she argued these documents demonstrated a material factual dispute. Id. Celotex then "argued that the three documents were inadmissible hearsay and thus could not be considered in opposition to the summary judgment motion" Id. The district court granted Celotex's summary judgment motion. Id. The appellate court reversed, holding that "petitioner's summary judgment motion was rendered 'fatally defective' by the fact that petitioner 'made no effort to adduce any evidence, in the form of affidavits or otherwise, to support its motion.'" Id. at 321, 106 S. Ct. at 2551-52. The Court held that a party seeking summary judgment did not always need to adduce factual evidence by affidavit in order to meet their initial procedural burden. See Celotex, 477 U.S. at 323. Rather, the Court held, it is enough for a party who would not bear the burden of proof at trial to "identify those portions of 'the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any,' that it believes demonstrate the absence of a genuine issue of material fact." Id. (quoting Fed. R. Civ. P. 56(c)). The burden then shifts to the nonmoving party to show, by "rebuttal affidavits, or other specified kinds of materials," that there is a genuine issue of material fact. Id. at 324.