know if anybody else had complained about the mat prior to your accident? A: No, neither. Again, Westwood did not attach any additional summary judgment evidence that conclusively negated the element of actual or constructive knowledge. Westwood merely argued that Castillo had no evidence that Westwood knew anything was wrong with the mat prior to her fall. As with the proximate cause element, West-wood is attempting — prematurely—to trigger a burden on Castillo to produce some evidence of actual or constructive knowledge before Westwood has met its own burden to negate the element; Westwood is attempting to focus on what Castillo failed to prove. In a traditional motion for summary judgment, this is improper. See HBO, A Div. of Time Warner Entertainment Co., L.P., 983 S.W.2d at 35 (<HOLDING>); American Tobacco Co., 951 S.W.2d at 435
holding that in a traditional motion for summary judgment the burden shifts to the nonmovant to raise a fact issue after the movant has facially established its right to judgment as a matter of law holding that once movant established right to summary judgment burden shifts to nonmovant to demonstrate otherwise holding that on appeal a nonmovant need not have answered or responded to the motion for summary judgment to contend that the movants summaiy judgment proof is insufficient as a matter of law to support summary judgment holding that movant is entitled to summary judgment when party with burden of proof fails to establish genuine fact issue holding that burden shifts to nonmovant to raise issue of fact