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A warehouse worker sued a chemical manufacturer in federal court, alleging that fumes from a cleaning solvent caused permanent lung injury. After a full discovery period, the manufacturer moved for summary judgment. The manufacturer did not offer its own medical expert. Instead, it cited the worker's interrogatory answers, expert disclosures, and deposition excerpts showing that the worker had disclosed no expert who would testify that the solvent can cause the disease or that it caused his disease.
The worker responded that his complaint alleged causation, that his breathing worsened after he used the solvent, and that he expected a jury to understand the timing. He attached an unsworn letter from a friend stating that the worker coughed after work. The worker did not request more discovery or identify admissible expert causation evidence. The worker also has a separate claim for unpaid wages based on time records that the manufacturer did not discuss in its motion.
How should the court rule? Discuss the movant's initial burden, the nonmovant's responsive burden, the use of circumstantial evidence, and whether summary judgment should extend beyond the causation-dependent claims.