Jonah Patel
A genuine issue of material fact is a legal concept that plays a crucial role in determining whether a case proceeds to trial or is resolved through summary judgment. It arises when two opposing parties disagree on facts that are legally relevant to a claim. For an issue to be considered genuine, the disagreement must be plausible and real, making a trial necessary for resolving the dispute. The burden of proof lies with the party asserting the existence of a genuine issue, who must provide substantial evidence to support their claim. Summary judgment procedures aim to efficiently dispose of cases where no genuine issue of material fact exists, allowing courts to grant judgments based on undisputed facts. However, when a genuine issue of material fact is present, it precludes summary judgment, as the outcome depends on the resolution of conflicting evidence. Understanding the distinction between genuine and non-genuine issues is essential for effectively navigating legal proceedings and ensuring that cases are decided based on the merits of the evidence presented.
| Characteristics | Values |
|---|---|
| Definition | A disagreement between opposing parties on facts that are legally relevant to a claim. |
| Nature of Disagreement | Must be "genuine" in the sense that it must be plausible. |
| Example | In a personal injury case, the plaintiff claims that the defendant's negligence caused their injuries. The defendant argues that they were not negligent and that the plaintiff's injuries were self-inflicted. |
| Role of Evidence | The person trying to win the case must prove their side with strong evidence. |
| Role of Judge | A judge cannot make a decision without a trial if there is a genuine issue of material fact. |
| Summary Judgment | A court may grant summary judgment when the party bringing the case fails to allege a genuine issue of material fact. |
| Triable Issue | An issue in which reasonable persons could disagree. |
| Material Fact | An issue of fact that could have a bearing on the outcome of the case under the applicable law. |
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What You'll Learn
A genuine issue is a triable issue
A genuine issue of material fact is a disagreement between opposing parties on facts that are legally relevant to a claim. It is a "triable issue", an issue in which reasonable persons could disagree. In other words, it is an issue that could allow a jury to return a verdict in favor of the non-moving party.
For example, in a personal injury case, the plaintiff claims that the defendant's negligence caused their injuries. The defendant argues that they were not negligent and that the plaintiff's injuries were caused by their own actions. The disagreement over the cause of the injuries is a genuine issue of material fact because it is legally relevant to the claim.
Another example is a breach of contract case, where the plaintiff claims that the defendant failed to deliver goods on time, causing a financial loss. If the court grants summary judgment in favor of the defendant, it would assume that the goods were delivered on time, which is a disputed fact.
The concept of a "genuine issue of material fact" is important in the context of motions for summary judgment. A summary judgment is a procedural vehicle to dispose of issues or claims in a lawsuit, either partially or fully. The moving party claims that there is no material fact and that they are entitled to a judgment as a matter of law. If there is a genuine issue of material fact, a judge cannot make a decision without a trial, and the person trying to win the case must prove their side with strong evidence.
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A material fact is essential to the plaintiff's cause of action
A "material fact" is one whose existence or non-existence may be essential to the plaintiff's cause of action under the applicable theory of recovery. In other words, it is a fact that is legally relevant to a claim. A "genuine issue" is a triable issue, one in which reasonable persons could disagree. Thus, a genuine issue of material fact is when two sides disagree about important facts that are relevant to a legal claim.
For example, in a personal injury case, the plaintiff claims that the defendant's negligence caused their injuries. Here, the plaintiff's cause of action is based on the defendant's negligence, which is a material fact. The defendant, on the other hand, argues that they were not negligent and that the plaintiff's injuries were caused by their own actions. This disagreement over the cause of the injuries is a genuine issue of material fact because it is legally relevant to the claim. If the court were to grant summary judgment in favour of the defendant, it would be assuming that the defendant was not negligent, which is a disputed fact.
Another example of a genuine issue of material fact can be seen in a case involving a road construction project. The plaintiff struck a manhole cover and, on the date the accident occurred, the defendant was performing roadwork in that area. The plaintiff testified that he believed he struck a manhole cover that was in a westbound lane, and provided photographs as evidence. However, the defendant introduced a Google Earth photo that showed a different manhole cover, indicating that the plaintiff may have struck a different cover than the one they claimed. The location of the manhole cover is a material fact because it is relevant to determining liability for the accident. The disagreement between the plaintiff and defendant over the location of the manhole cover constitutes a genuine issue of material fact.
In the context of motions for summary judgment, it is important to focus on and frame arguments around the facts that are considered "material." These are the facts that could have a bearing on the outcome of the case and should be introduced and emphasised at trial. If there is a genuine issue of material fact, a judge cannot make a decision without a trial, as the person trying to win the case must prove their side with strong evidence.
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The burden of proof shifts to the non-moving party
The burden of proof is a legal concept that requires a party to produce evidence to establish the truth of facts needed to satisfy all the required elements of a legal dispute. The burden of proof usually falls on the party making the claim or bringing the case to court. In a criminal case, the burden of proof is on the prosecutor, and the defendant is presumed innocent. In a civil suit, the plaintiff bears the burden of proof that the defendant's action or inaction caused them injury.
In some cases, the burden of proof can shift to the non-moving party. This occurs when the moving party presents a prima facie case showing that there is no genuine issue over a material fact. A genuine issue of material fact exists when two sides disagree about important facts relevant to a legal claim. This disagreement must be real and plausible. For example, in a personal injury case, the plaintiff may claim that the defendant's negligence caused their injuries, while the defendant argues that they were not negligent and that the plaintiff's injuries resulted from their own actions. The disagreement over the cause of the injuries is a genuine issue of material fact because it is legally relevant to the claim.
If the moving party can make a prima facie case that there is no genuine issue of material fact, the burden of proof shifts to the non-moving party to refute this claim. The non-moving party must provide substantial evidence to raise a genuine issue over a material fact and avoid summary judgment. Summary judgment is a procedure used to promptly dispose of actions where there is no genuine issue of material fact. It is used to assess the proof and determine whether there is a genuine need for a trial.
The shifting of the burden of proof allows for flexibility in courtroom procedures and is particularly useful in areas where fault or evidence is challenging to establish. It enables the non-moving party to make counterpoints and present their evidence before a judge or jury decides the issue. This process ensures that all relevant facts are considered and that both parties have an opportunity to support their claims or defences.
It is important to note that the burden of proof can also shift in criminal cases, although this is less common. In some circumstances, the burden of persuasion may shift to the defendant when specific elements of a plaintiff's claim can be characterised as affirmative defences or exemptions.
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Summary judgment cannot be granted if there is a genuine issue
A "genuine issue of material fact" is a disagreement between opposing parties on facts that are legally relevant to a claim. The disagreement must be "genuine" in the sense that it must be plausible. In other words, a genuine issue of material fact is when two sides disagree about important facts that are relevant to a legal claim. This disagreement must be real and make sense.
For example, in a personal injury case, the plaintiff claims that the defendant's negligence caused their injuries. The defendant argues that they were not negligent and that the plaintiff's injuries were caused by their own actions. The disagreement over the cause of the injuries is a genuine issue of material fact because it is legally relevant to the claim.
A motion for summary judgment is a procedural vehicle to try to dispose of issues or claims in a lawsuit, either partially or fully. The objective is for the moving party to claim that there is no material fact and that they are entitled to a judgment as a matter of law. A court is authorized to grant a "summary judgment" when the party bringing the case fails to allege a genuine issue of a material fact.
However, summary judgment cannot be granted if there is a genuine issue of material fact. This is because a genuine issue of material fact precludes summary judgment, which is proper if there is no genuine issue of material fact and the moving party is entitled to a judgment as a matter of law. The very mission of the summary judgment procedure is to pierce the pleadings and assess the proof to determine whether there is a genuine need for a trial. If there is a genuine issue of material fact, a judge cannot make a decision without a trial, and the person trying to win the case must prove their side with strong evidence.
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A genuine issue must be plausible
A genuine issue of material fact is a disagreement between opposing parties on facts that are legally relevant to a claim. This disagreement must be real and plausible. It is not enough for the parties to simply assert contradictory positions; the dispute must be reasonable and based on strong evidence.
For example, in a personal injury case, a plaintiff may claim that the defendant's negligence caused their injuries. The defendant may counter that they were not negligent and that the plaintiff's injuries resulted from their own actions. This disagreement over the cause of the injuries constitutes a genuine issue of material fact because it is legally relevant to the claim. It is a plausible dispute that could influence the outcome of the case.
In another instance, a plaintiff might claim that the defendant failed to deliver goods on time, resulting in financial losses for the plaintiff. Here, the defendant's timely delivery of the goods becomes a genuine issue of material fact. If the court were to rule in favour of the defendant without addressing this dispute, it would assume the timely delivery of the goods, which is a contested fact.
The concept of a "genuine issue" is often associated with the term "triable issue". This refers to situations where reasonable people could disagree. For example, consider a scenario where well-qualified experts present opposing opinions, each supported by sufficient facts and data. This scenario represents a reasonable disagreement and qualifies as a triable issue.
When determining whether a dispute constitutes a genuine issue of material fact, it is crucial to focus on the facts that are likely to influence the outcome of the case. These facts should be emphasised and framed accordingly when moving for or defending against a summary judgment.
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Frequently asked questions
A genuine issue of material fact is when two sides disagree about important facts that are relevant to a legal claim. This disagreement must be real and make sense.
If there is a genuine issue of material fact, a judge cannot make a decision without a trial.
They must prove their side of the story with strong evidence.
In a personal injury case, the plaintiff claims that the defendant's negligence caused their injuries. The defendant argues that they were not negligent and that the plaintiff's injuries were self-inflicted. The disagreement over the cause of the injuries is a genuine issue of material fact because it is legally relevant to the claim.
