Sartor et al. v. Arkansas Natural Gas Corp.
321 U.S. 620 (1944)
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Rule of Law:
Summary judgment is improper when the moving party's supporting evidence consists of affidavits from interested expert witnesses whose credibility is a central issue. The weight and credibility of such opinion testimony are questions of fact for the jury to determine at trial.
Facts:
- In March 1927, the Sartors leased their land in Richland Parish, Louisiana, to Arkansas Natural Gas Corp. for natural gas development.
- The lease stipulated that the Sartors would be paid a royalty of one-eighth of the value of the gas, calculated at the 'market price' but no less than 3 cents per thousand cubic feet (mcf).
- For many years, the lessee paid royalties at the minimum 3-cent rate.
- The Sartors contended that from 1927 through 1932, the actual market price for gas at the wellhead was considerably higher than 3 cents per mcf.
- The dispute centered on determining the true market price at the wellhead, a location and time where few commercial sales actually occurred, making valuation difficult.
- Gas producers, including the lessee, typically sold the gas at delivery points distant from the wellhead for prices substantially higher than the 3-cent royalty rate.
Procedural Posture:
- The Sartors (plaintiffs) sued Arkansas Natural Gas Corp. (defendant) in federal district court to recover unpaid gas royalties.
- After a trial concerning a later time period (1930-1933), a jury found the market price was higher than 3 cents, and the Circuit Court of Appeals affirmed that verdict.
- The Circuit Court of Appeals also reversed the trial court's dismissal of the claims for the period before March 20, 1930, and remanded the case for trial on that issue.
- On remand to the district court, the defendant filed a motion for summary judgment on the claims for the pre-1930 period.
- The district court granted the defendant's motion for summary judgment.
- The plaintiffs (appellants) appealed to the Circuit Court of Appeals, which affirmed the district court's grant of summary judgment.
- The plaintiffs then petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does Federal Rule of Civil Procedure 56 permit a court to grant summary judgment when the moving party relies on opinion evidence from interested expert witnesses to establish that there is no genuine issue of material fact?
Opinions:
Majority - Mr. Justice Jackson
No, Rule 56 does not permit summary judgment in these circumstances. A summary disposition should only be granted on evidence that a jury would not be at liberty to disbelieve and that would require a directed verdict for the moving party. The defendant's motion for summary judgment was supported almost exclusively by affidavits from expert witnesses who were its own officers or executives of similarly situated gas companies. The credibility of these interested witnesses is a material fact in itself, which must be tested by cross-examination and evaluated by a jury. Opinion evidence, especially from biased sources, is not conclusive and does not eliminate a genuine issue for trial, even if uncontradicted. The jury is the proper arbiter of witness credibility and the weight to be given their testimony.
Dissenting - Mr. Chief Justice Stone
Yes, summary judgment was appropriate in this case. The plaintiffs had the burden to show that the market price at the wellhead exceeded 3 cents, and they failed to produce any probative evidence to support this claim. The defendant, in contrast, presented affidavits and records showing all wellhead sales were at 3 cents or less. The plaintiffs' only counter-evidence concerned pipeline prices, which Louisiana courts had already held were irrelevant to determining the wellhead price. Since the plaintiffs failed to present evidence creating a genuine dispute on the decisive issue, and did not utilize discovery procedures to challenge the defendant's experts, summary judgment serves its proper function of terminating groundless litigation.
Analysis:
This case significantly curtails the use of summary judgment, establishing that it cannot be used to resolve disputes where the credibility of the moving party's witnesses is a key factor. It reinforces the jury's paramount role as the trier of fact, particularly concerning witness credibility and the weight of expert testimony. The decision makes it more difficult for a party to win a case before trial simply by submitting self-serving affidavits, ensuring that potentially biased witnesses must face cross-examination. This precedent protects the right to a jury trial in cases involving subjective questions of value, intent, or any issue turning on the believability of interested parties.
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