Celotex Corp. v. Catrett

Facts

Catrett sued fifteen corporations in federal court, alleging that her husband Louis Catrett died in 1979 from exposure to their asbestos products. Celotex moved for summary judgment. It argued that she had failed to produce evidence that any Celotex product caused the injuries alleged within the jurisdictional limits of the District Court. It pointed to her interrogatory answers, which named no witness who could testify about the decedent's exposure to its asbestos products. In response, Catrett produced three documents: a transcript of the decedent's deposition, a letter from an official of one of his former employers, and a letter from an insurance company to her attorney. She claimed they showed a genuine factual dispute about whether the decedent had ever been exposed to Celotex products. The Court described them as tending to show exposure to Celotex products in Chicago during 1970-1971. Celotex answered that the three documents were inadmissible hearsay and could not be counted against its motion.

Issues

1. Must a party moving for summary judgment support its motion with affidavits or other evidence negating the opponent's claim?
2. After adequate time for discovery, must summary judgment be entered, upon motion, against a party who fails to make a showing sufficient to establish an element essential to her case on which she will bear the burden of proof at trial?

Holding

Celotex's motion was not defective for lacking supporting affidavits. Where the nonmoving party will bear the burden of proof at trial on a dispositive issue, a movant may rely solely on the pleadings, depositions, answers to interrogatories and admissions on file to point out that there is no evidence supporting that party's case. The Court of Appeals erred by holding that the movant must always produce affirmative evidence negating the claim.