River Birch, Incorporated, et al. v. Waste Management of Louisiana, L.L.C.
CriminalProcedure JusticiabilityDoctri
Whether the holding in Matsushita Electrical Industrial Co. v. Zenith Radio Corp. that 'ambiguous' circumstantial evidence does not support an inference of wrongdoing is limited to the antitrust context or states a general summary judgment standard applicable to all cases under Federal Rule of Civil Procedure 56
QUESTION PRESENTED In Matsushita Electrical Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, 588 (1986), this Court held that “ambiguous” circumstantial evidence— evidence that is “as consistent with” an innocent explanation as it is with liability—“does not, standing alone, support an inference” of wrongdoing. Instead, to survive summary judgment, a plaintiff must also present “evidence that tends to exclude” the innocent explanation. Jd. (quotation omitted). The question presented is whether that holding is limited to the antitrust context (as the court below held), or whether it instead states a general summary judgment standard applicable to all cases under Federal Rule of Civil Procedure 56.