of and (the final judgment rule). To defeat a summary-judgment motion, the non-moving party only has to show substantial evidence that a dispute of material facts exists, regardless of the strength of that evidence. For example, even if the moving side can produce the testimony of "a dozen bishops", and the non-moving side only has the testimony of a known liar, then summary judgment is not appropriate. Deciding on the relative credibility of witnesses is a question for the factfinder at trial. Where appropriate, a court may award judgment summarily upon fewer than all claims. This is known as partial summary judgment. It is not uncommon for summary judgments of lower U.S. courts in complex cases to be overturned on appeal. A grant of summary judgment is reviewed de novo (meaning, without deference to the views of the trial judge) both as to the determination that there is no remaining genuine issue of material fact and that the prevailing party was entitled to judgment as a matter of law. State-court practice Summary-judgment practice in state courts in most U.S. states is similar to federal practice, though with minor differences. For example, the U.S. state of California requires the moving party to actually present evidence rather than merely refer to evidence. See Aguilar v. Atlantic Richfield Co., 25 Cal. 4th 826 (2001). This is done by attaching relevant documents and by summarizing all relevant factual points within those documents in a separate statement of facts. In turn, the record to be reviewed by the judge can be very large; for example, the Aguilar case involved a record of about 18,400 pages. Also, California uses the term "summary adjudication" instead of "partial summary judgment". The California view is that the latter term is an oxymoron since a judgment is supposed to be final (in the sense of completely disposing of the case). There is currently a conflict between the different districts of the California Courts of Appeal as to the availability of summary adjudication; most superior courts tend to side with the narrowest interpretation of California Code of Civil Procedure section 437c, under which a party may make such a motion only with respect to an entire cause of action, an affirmative defense, or a punitive-damages claim. There is also language in section 437c about "issues of duty", but some Court of Appeal panels have given that phrase an extremely narrow interpretation