Due Process—Civil Sanctions

Goodyear Tire & Rubber Co. v. Haeger, No. 15-1406

After Goodyear Tire & Rubber Co. conceded withholding damaging information that was responsive to discovery requests, a federal district court entered sanctions, requiring Goodyear to pay the plaintiffs’ attorneys’ fees from the time of the first misrepresentation to the end of the case.  The district court acknowledged that not all of those fees had been caused by Goodyear’s misconduct but deemed the sanction appropriate, as an exercise of the court’s inherent powers, given the egregiousness of the violation.  The court of appeals affirmed.  Today, the Supreme Court vacated the discovery sanction, holding that a party sanctioned for bad-faith conduct can be taxed only for fees that the aggrieved party would not have incurred but for the bad faith.  The decision, authored by Justice Kagan, was unanimous (save for the newly confirmed Justice Gorsuch, who did not participate in the case).