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Keywords

discoveryappealtrustwillcomplianceantitrustbad faithwrit of certiorari
plaintiffdiscoveryappealpleabad faithrespondentwrit of certiorari

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National Hockey League v. Metropolitan Hockey Club, Inc., 427 U.S. 639, 96 S.Ct. 2778, 49 L.Ed.2d 747, 21 Fed.R.Serv.2d 1027, 1976-1 Trade Cases P 60,941

Facts

The case arose from the dismissal of an antitrust action by the professional hockey club against the competing league due to the club's failure to timely respond to written interrogatories as ordered by the District Court. Despite numerous extensions and warnings, the club did not comply with the discovery order, leading the District Court to conclude that the club's conduct demonstrated a callous disregard for its responsibilities. The Court of Appeals found insufficient evidence of bad faith, but the Supreme Court disagreed.

The District Court, in its memorandum opinion directing that respondents' complaint be dismissed, summarized the factual history of the discovery proceeding in these words: 'After seventeen months where crucial interrogatories remained substantially unanswered despite numerous extensions granted at the eleventh hour and, in many instances, beyond the eleventh hour, and notwithstanding several admonitions by the Court and promises and commitments by the plaintiffs, the Court must and does conclude that the conduct of the plaintiffs demonstrates the callous disregard of responsibilities counsel owe to the Court and to their opponents.'

Issue

Whether the Court of Appeals was correct in concluding that the District Court abused its discretion in dismissing the antitrust action for failure to comply with discovery orders.

The question presented is whether the Court of Appeals was correct in so concluding.

Rule

Under Fed.Rule Civ.Proc. 37, a court may impose sanctions, including dismissal, for failure to comply with discovery orders, particularly when such failure is due to bad faith or willfulness.

Rule 37 provides in pertinent part as follows: 'If a party . . . fails to obey an order to provide or permit discovery . . . the court in which the action is pending may make such orders in regard to the failure as are just, and among others the following: (C) An order striking out pleadings or parts thereof, or staying further proceedings until the order is obeyed, or dismissing the action or proceeding or any part thereof, or rendering a judgment by default against the disobedient party.'

Analysis

The Supreme Court analyzed the District Court's findings and determined that the dismissal was justified due to the hockey club's flagrant bad faith and the inadequate responses provided. The Court emphasized that the District Court had been patient and had given ample time for compliance, but the club's actions demonstrated a disregard for the court's authority and the discovery process.

We think that the comprehensive memorandum of the District Court supporting its order of dismissal indicates that the court did just that. That record shows that the District Court was extremely patient in its efforts to allow the respondents ample time to comply with its discovery orders.

Conclusion

The Supreme Court granted the petition for a writ of certiorari and reversed the judgment of the Court of Appeals, affirming the District Court's dismissal of the action.

Therefore, the petition for a writ of certiorari is granted and the judgment of the Court of Appeals is reversed.

Who won?

The competing professional hockey league prevailed in the case because the Supreme Court upheld the District Court's dismissal of the hockey club's action due to its bad faith in failing to comply with discovery orders.

The Supreme Court held that the record established that, under the circumstances, the district judge did not abuse his discretion in finding bad faith on the part of the hockey club for failing to timely answer the interrogatories and in concluding that the extreme sanction of dismissal was appropriate by reason of the hockey club's flagrant bad faith and its counsel's callous disregard of its responsibilities.

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