at 1186. “A sanction counts as compensatory only if it is ‘calibrate to damages caused by’ the bad-faith acts on which it is based.
The Court emphasized that such sanctions must be compensatory rather than punitive in nature. Writing for a unanimous Court (with the exception of Justice Gorsuch who did not participate), Justice Elena Kagan stated: “A district court has broad discretion to calculate fee awards under standard. But because the court here granted legal fees beyond those resulting from the litigation misconduct, its award cannot stand.” Id.
Who discovered theine full#
at 1189 (alterations). In support of its award, the district court also concluded that full and timely disclosure of the withheld test results would likely have led Goodyear to settle the case much earlier. without any need to find a ‘causal link between the sanctionable conduct.’” Id. all of the attorneys' fees incurred in the case be awarded. Silver found that Goodyear and its attorneys had “engaged in a ‘years-long course’ of bad-faith behavior.” Id. Exercising its inherent authority to sanction bad faith litigation, the district court awarded the Haeger family $2.7 million. Despite acknowledging that in the “usual case, sanctions ordered pursuant to a court's inherent power to sanction litigation misconduct must be limited to the amount of legal fees caused by that misconduct” Judge Silver nevertheless determined that “the sanctionable conduct r to a truly egregious level. Thereafter, the family sought sanctions (attorney’s fees and costs) for Goodyear’s knowing concealment, discovery fraud and bad faith litigation.Īrizona Senior District Court Judge Roslyn O. at 1184. Goodyear conceded withholding the information despite a direct request for all testing regarding the subject model tire. The undisclosed G159 testing revealed the G159 tire “got unusually hot” at highway speeds.
Who discovered theine trial#
On the first day of trial in April 2010, the parties informed the court that a settlement had been reached. Months after the settlement, the family’s lawyer discovered G159 tire testing from another lawsuit, which had not been produced in the subject litigation. Discovery in the case was contentious and lasted several years. A key issue in the contentious discovery process involved repeated requests for internal G159 tire testing, which Goodyear was persistently slow to respond to. 18, 2017). The decision carries significant implications in the context of discovery violation jurisprudence as well as a curb on a district court’s inherent sanctioning authority.īy way of background, the litigation arose from the Haeger family’s action against Goodyear, alleging the failure of a Goodyear G159 tire caused the family’s motorhome to swerve off the road and flip over.
Supreme Court made a bold and seemingly manufacturer-friendly pronouncement in overturning a federal district court judge’s $2.7 million award in sanctions against manufacturer Goodyear Tire & Rubber Company for a purported discovery violation.
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