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A trilogy from the 1980s that involved summary judgments, not George Lucas (Celotex v. Catrett)

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Quimbee Case of the Week: Celotex v. Catrett

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Before the 2010 amendment to the Federal Rule of Civil Procedure, Rule 56(c) authorized entry of summary judgment on a party’s behalf “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”

The United States Supreme Court’s decision in Celotex Corp. v. Catrett, 477 U.S. 317 (1986), construing that rule would become one of the most important and often cited cases on federal civil procedure. Along with Anderson v. Liberty Lobby, 477 U.S. 242 (1986), and Matsushita Electric Industries Co. v. Zenith Radio Corp., 475 US 574 (1986), Celotex is part of what has come to be known as the 1986 Trilogy setting forth the substantive standards for Rule 56 summary judgments.

The court’s holding that a party need not provide affirmative evidence that there is an absence of material facts in dispute in order to prevail on a summary judgment motion greatly expanded the availability of summary judgments in federal courts. What’s more, the Advisory Committee notes to the 2010 Amendments to the Federal Rules make clear that the Celotex standard is still good law.

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