Celotex Summary Judgment Standard

The Celotex standard for summary judgment, established in Celotex Corp. v. Catrett (1986), clarified the burden on the moving party under Federal Rule of Civil Procedure 56. The case is part of a trilogy of summary judgment cases decided in the same term (along with Anderson v. Liberty Lobby and Matsushita v. Zenith) that collectively made summary judgment a more accessible tool for defendants.

Under Celotex, a party moving for summary judgment does not need to produce affirmative evidence negating the non-moving party's claim. Instead, the movant can simply "point out to the district court that there is an absence of evidence to support the nonmoving party's case." This shifted the understanding of the movant's initial burden — the movant need only identify the absence of a genuine issue of material fact.

Once the moving party meets this initial burden, the burden shifts to the non-moving party to come forward with specific facts showing that there is a genuine dispute requiring trial. The non-moving party cannot rest on mere allegations, conclusory statements, or speculation — they must present affirmative evidence. The court must view the evidence in the light most favorable to the non-moving party and draw all reasonable inferences in their favor.

A genuine dispute of material fact exists when the evidence is such that a reasonable jury could return a verdict for the non-moving party. A fact is "material" if it could affect the outcome of the case under the governing law. A dispute is "genuine" if the evidence would allow a reasonable jury to find for either party.

Summary judgment serves an important gatekeeping function — it prevents cases with insufficient evidence from consuming judicial and party resources through trial. However, it should not be used to resolve genuine factual disputes that are properly the province of the jury.

On exams, summary judgment analysis requires students to identify the moving party's burden, determine whether that burden has been met, and then assess whether the non-moving party has produced sufficient evidence of a genuine dispute.