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Keywords

plaintiffdefendantlawyerhearingtrialcivil procedure

plaintiffnegligencetrialpleamotionrespondent

Related Cases

Link v. Wabash R. Co., 370 U.S. 626, 82 S.Ct. 1386, 8 L.Ed.2d 734, 6 Fed.R.Serv.2d 831

Facts

The action began on August 24, 1954, following a collision between the plaintiff's automobile and a train operated by the defendant. After several years of delays, the District Court scheduled a pretrial conference for October 12, 1960. On the day before the conference, the plaintiff's counsel informed the defendant's lawyer that he might not attend due to other commitments. When the counsel failed to appear at the conference, the District Court dismissed the case for failure to prosecute, citing the counsel's inadequate excuse and the case's history.

The action, growing out of a collision between petitioner's automobile and one of respondent's trains, was commenced on August 24, 1954. Some six years later, and more than three years after petitioner had finally prevailed on respondent's motion for judgment on the pleadings (during which time two fixed trial dates had been postponed), the District Court, on September 29, 1960, duly notified counsel for each side of the scheduling of a pretrial conference to be held at the courthouse in Hammond, Indiana, on October 12, 1960, at 1 p.m.

Issue

Did the District Court have the authority to dismiss the case sua sponte for failure to prosecute without providing notice or an adversary hearing?

Petitioner challenges, from the standpoint of both power and discretion, the District Court's sua sponte dismissal of this diversity negligence action under circumstances that follow.

Rule

A federal trial court has the inherent power to dismiss a plaintiff's action with prejudice due to failure to prosecute, which is necessary to prevent undue delays and manage court calendars. This power is recognized in Federal Rule of Civil Procedure 41(b), which allows for involuntary dismissal for failure to prosecute.

The authority of a federal trial court to dismiss a plaintiff's action with prejudice because of his failure to prosecute cannot seriously be doubted.

Analysis

The Supreme Court found that the District Court acted within its discretion in dismissing the case, as the plaintiff's counsel failed to provide a reasonable explanation for his absence at the pretrial conference. The Court noted that the history of the case indicated a pattern of dilatory conduct, justifying the dismissal. The absence of prior notice or a hearing was deemed acceptable under the circumstances, as the counsel had been adequately informed of the conference and its importance.

On this record we are unable to say that the District Court's dismissal of this action for failure to prosecute, as evidenced only partly by the failure of petitioner's counsel to appear at a duly scheduled pretrial conference, amounted to an abuse of discretion.

Conclusion

The Supreme Court affirmed the dismissal of the case, concluding that the District Court did not abuse its discretion in dismissing the action for failure to prosecute.

Affirmed.

Who won?

Wabash Railroad Company prevailed in the case because the Supreme Court upheld the District Court's dismissal of the plaintiff's action for failure to prosecute, finding no abuse of discretion.

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