Coury v. City of Tampa
After the close of discovery, the City moved for summary judgment arguing simply that Coury lacked evidence to support his negligent hiring/training/supervision claims; Coury filed no evidence in response, contending the City never met its initial burden of production. The Second District affirmed, holding that under amended rule 1.510 and the Celotex standard, a movant who does not bear the trial burden need not produce any evidence and may discharge its 'far from stringent' initial burden by pointing out the absence of record evidence, at which point the burden shifts to the nonmovant.
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