J.F. Edwards Construction Co. v. Anderson Safeway Guard Rail Corp.

Brief Fact Summary.

The parties were directed to file a stipulation of facts and pretrial order. Anderson did not agree to the stipulated facts. The district court, granted a motion to strike Anderson’s pleadings, among other things; a judgment of over $89,000 was also entered against Anderson the day after the court entered the foregoing relief. Anderson’s motions to vacate the judgments, for a new trial, and for other relief were denied. Anderson appealed.

Synopsis of Rule of Law.

Federal Rule of Civil Procedure 16 does not compel a stipulation of facts; sanctions for failure to file one may not be imposed by the court.

Facts.

The parties were directed to file a stipulation of facts and pretrial order. Edwards and Westinghouse (the defendant in a consolidated action brought by Anderson) agreed to a stipulation; Anderson did not. The district court imposed sanctions including the grant of a motion to strike Anderson’s pleadings, among other things; a judgment of over $89,000 was also entered against Anderson. Anderson’s motions to vacate the judgments, for a new trial, and for other relief were denied. Anderson appealed.

Issue.

Were the sanctions imposed upon Anderson permissible?

Held.

No. Anderson’s failure to agree to the stipulation of facts did not justify dismissal of its claims; it was also improper to enter judgment against Anderson on its counterclaim and against it on Edwards’ amended complaint.

Discussion.

A court has narrowly circumscribed power to compel obedience to requests and demands based on Federal Rule of Civil Procedure 41(b) or the court’s inherent power to manage its calendar; these powers do not support the sanctions imposed in this case, however, and judicial compulsion was not allowed under the facts as presented.