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Keywords

plaintifflitigationattorneydiscoverystatuteappealdiscriminationclass actioncivil rightsbad faithstatutory interpretation

litigationlawyerstatuteappealclass actioncivil rightsbad faithstatutory interpretation

Related Cases

Roadway Exp., Inc. v. Piper, 447 U.S. 752, 100 S.Ct. 2455, 65 L.Ed.2d 488, 23 Fair Empl.Prac.Cas. (BNA) 12, 23 Empl. Prac. Dec. P 31,025, 29 Fed.R.Serv.2d 733

Facts

In June 1975, two former employees and one unsuccessful job applicant filed a civil rights class action against Roadway Express, Inc., alleging racial discrimination in employment. The plaintiffs' attorneys, Robert E. Piper, Jr., Frank E. Brown, Jr., and Bobby Stromile, failed to comply with multiple court orders regarding discovery, including not answering interrogatories and not submitting required briefs. As a result, Roadway moved to dismiss the suit and sought attorney's fees, leading to the District Court's dismissal of the case with prejudice and an order for the plaintiffs' attorneys to pay Roadway's costs and fees.

In June 1975, two former employees and one unsuccessful job applicant brought a civil rights class action against petitioner Roadway Express, Inc. (Roadway).

Issue

Whether federal courts have the statutory or inherent power to tax attorney's fees directly against counsel who have abused the processes of the courts.

This case involves the problem of what sanctions may be imposed on lawyers who unreasonably extend court proceedings.

Rule

The Supreme Court ruled that 28 U.S.C. § 1927 does not authorize the imposition of attorney's fees against counsel for vexatiously multiplying litigation, and that attorney's fees can be awarded as sanctions under Rule 37 for failure to comply with discovery orders.

The general rule is that a litigant cannot recover his counsel fees, but that rule does not apply when the opposing party has acted in bad faith, including bad faith in the conduct of the litigation.

Analysis

The Court analyzed the statutory interpretation of 28 U.S.C. § 1927 and concluded that it does not include attorney's fees as part of the 'costs' that can be taxed against counsel. The Court emphasized that the civil rights statutes allow for attorney's fees to be awarded only to prevailing parties and that § 1927 is focused on attorney conduct without regard to the outcome of the case. The Court also noted that the inherent power of federal courts to assess attorney's fees against counsel is limited to cases of bad faith, which was not established in this instance.

The statutory interpretation proposed by Roadway not only runs counter to the apparent intent of Congress in 1813 and 1853, but also could introduce into the statute distinctions unrelated to its goal.

Conclusion

The Supreme Court affirmed the Court of Appeals' ruling on § 1927 and remanded the case for further proceedings regarding the potential recovery of costs and attorney's fees under Rule 37.

We affirm the ruling of the Court of Appeals on § 1927.

Who won?

Roadway Express, Inc. prevailed in the case because the Supreme Court upheld the dismissal of the plaintiffs' action and the order for the plaintiffs' attorneys to pay costs and fees under Rule 37.

Roadway also contends that the District Court's ruling was a proper exercise of the court's inherent powers.

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