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injunctionappeal
injunctionappeal

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Burlington Northern R. Co. v. Department of Revenue of State of Wash., 934 F.2d 1064, 20 Fed.R.Serv.3d 475

Facts

In 1989, Burlington Northern Railroad Company filed a complaint against the Washington Department of Revenue, alleging that the ad valorem taxes assessed on its personal property were discriminatory and violated the Railroad Revitalization and Regulatory Reform Act. The district court transferred the case to a special master, who concluded that Burlington had not established discriminatory taxation and denied the preliminary injunction. Burlington appealed this decision, arguing that the district court had abused its discretion in referring the case to a special master.

In 1989, Burlington Northern Railroad Company filed a complaint against the Washington Department of Revenue, alleging that the ad valorem taxes assessed on its personal property were discriminatory and violated the Railroad Revitalization and Regulatory Reform Act. The district court transferred the case to a special master, who concluded that Burlington had not established discriminatory taxation and denied the preliminary injunction.

Issue

Did the district court abuse its discretion by referring the entire case to a special master, and was the denial of the preliminary injunction justified?

Did the district court abuse its discretion by referring the entire case to a special master, and was the denial of the preliminary injunction justified?

Rule

The use of special masters is restricted to situations where they are necessary to aid judges in the performance of specific judicial duties, and a reference to a master should only occur under exceptional circumstances.

The use of masters, however, is restricted to situations where they are necessary 'to aid judges in the performance of specific judicial duties, as they may arise in the progress of a cause….'

Analysis

The Court of Appeals found that the district court's reference of the entire case to a special master was not justified by exceptional circumstances. The court noted that the district court acted as a mere rubber stamp for the master's findings and conclusions, which constituted an abdication of its judicial responsibility. The court emphasized that the circumstances did not warrant such a significant delegation of judicial power.

The Court of Appeals found that the district court's reference of the entire case to a special master was not justified by exceptional circumstances. The court noted that the district court acted as a mere rubber stamp for the master's findings and conclusions, which constituted an abdication of its judicial responsibility.

Conclusion

The Court of Appeals reversed the district court's decision and remanded the case for initial consideration, concluding that the district court had abused its discretion in referring the case to a special master.

The Court of Appeals reversed the district court's decision and remanded the case for initial consideration, concluding that the district court had abused its discretion in referring the case to a special master.

Who won?

Burlington Northern Railroad Company prevailed in the case because the Court of Appeals found that the district court had abused its discretion in referring the case to a special master and failing to properly consider the preliminary injunction.

Burlington Northern Railroad Company prevailed in the case because the Court of Appeals found that the district court had abused its discretion in referring the case to a special master and failing to properly consider the preliminary injunction.

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