Featured Case: Campbell Helps Establish Celotex Standard in MA
While the claim was relatively minor, this case established the Celotex Standard of Summary Judgment in MA, which allows Summary Judgment if there are no facts to support that a particular event actually happened. Instead of hinging on a factual dispute, there were not facts available to use and facts would never be available. Prior to this case, the Federal courts had established the Celotex standard on a federal level, but not at the state level.
The Supreme Judicial Court took the case so it could establish the Celotex Standard in MA and this case interprets how the rule will be applied.
The plaintiff filed a complaint against both the manufacturer of the automobile and the rental agency which sold the car to the plaintiff, in which he alleged that a design defect caused the fire that completely destroyed the vehicle.
After the Superior Court, Hampden County, dismissed the count for treble damages and granted summary judgment in favor of both defendants on remaining counts, the plaintiff appealed. The Supreme Judicial Court held that: (1) complaint which alleged that plaintiff purchased automobile from rental agency failed to state cause of action for treble damages against manufacturer with whom plaintiff had no purchaser-seller relationship, and (2) summary judgment on remaining product liability claims was proper given complete failure of proof concerning essential element of claim, namely existence of defect in vehicle at time of purchase.
