In this Note, the difficulties judges encounter in applying the Celotex standards are illustrated through an examination of summary judgment decisions in the United States Supreme Court and in Ohio courts. Ohio's judges often look to the Supreme Court's interpretations of the Federal Rules of Civil Procedure for guidance in applying Ohio's summary judgment rule, and summary judgment decisions of this state therefore exemplify the pitfalls that the Supreme Court has created.
Note, Summary Judgment and Problems in Applying the Celotex Trilogy Standard, 42 Clev. St. L. Rev. 263 (1994)