E-Alert Case Updates
U.S. District Court Examines Docket Management Authority Under FRCP 41(b)
Amir Fatir v. Walter Redman, et al.
In Amir Fatir v. Walter Redman, et al., a case involving a motion to enforce a judgment issued in 1977, the United States District Court for the District of Delaware concluded that enforcement of the judgment was not warranted and that dismissal of the underlying case was appropriate under Federal Rule of Civil Procedure 41(b). Thus, Judge Gregory M. Sleet denied the movant’s Motion to Enforce Judgment and dismissed the case.
By way of factual background, on October 29, 1976, convicted inmates at the Delaware Correctional Center (“DCC”) filed a 42 U.S.C. § 1983 claim in the United States District Court for the District of Delaware seeking injunctive relief to alleviate overcrowded conditions at the DCC. See Anderson v. Redman, 474 F. Supp. 511, 513 (D. Del. 1979). On December 6, 1976, the court found that the conditions at the DCC could not pass constitutional muster and granted immediate relief to alleviate the overcrowding. On February 17, 1977, the court entered a final order that granted the plaintiffs permanent injunctive relief and required that the defendants limit the inmate population of the DCC to the design capacity of that institution. On March 17, 1977, the court entered an order denying the defendants’ application for a partial stay.
In response to the court’s March 1977 order, on June 8, 1979, the Governor of Delaware signed into law House Bill 495 ("H.B. 495"). H.B. 495 was designed to prevent the court from enforcing limits on the inmate population in the State of Delaware. Following the enactment of H.B. 495, the defendants moved to vacate the February 17, 1977 order, on the grounds that the law had undercut the basis of that order. The plaintiffs, on the other hand, sought a stay of the court's order pending resolution of a State court action that they had filed to challenge the constitutionality of H.B. 495 under the Delaware Constitution.
On November 28, 1979, the court denied the defendants’ motion to vacate. The court ordered the plaintiffs to litigate all bases for their Delaware State constitutional challenge to H.B. 495 in the Delaware courts and stayed the February 17, 1977 order until 90 days after the ultimate resolution of the State court action. In accordance with the order to litigate in State court, the plaintiffs filed a class action in the Court of Chancery of Delaware, New Castle County, in March of 1980. (Dickerson v. DuPont, Civ. A. No. 10256 (Del. Ch.)) (“Dickerson”). The parties ultimately reached a settlement agreement in the Dickerson case to alleviate overcrowded conditions at the DCC and the Court of Chancery entered an order approving the agreement on November 28, 1988. The agreement contemplated implementation of its provisions over three years ending in 1991. The Dickerson class action was dismissed on September 7, 1995.
No further action in Anderson v. Redman, took place until September 22, 2014, when Fatir filed a motion to enforce the February 17, 1977 judgment pursuant to Federal Rule of Civil Procedure 70 and 71, seeking an order for the defendants to reduce the DCC inmate capacity to the design capacity. The defendant Warden Pierce opposed the motion.
Federal Rule of Civil Procedure 70 states in pertinent part: "If a judgment directs a party to ... perform any ... specific act and the party fails to comply within the time specified, the court may direct the act to be done at the cost of the disobedient party by some other person ... The court may also in proper cases adjudge the party in contempt." Federal Rule of Civil Procedure 71 provides that "when an order grants relief for a nonparty or may be enforced against a nonparty, the procedure for enforcing the order is the same as for a party."
The court first noted that until Fatir filed the motion under consideration, no action had been taken in this matter for approximately thirty years. The court then discussed its ability to dismiss an action pursuant to Federal Rule of Civil Procedure 41(b) based upon its “inherent power to manage it docket,” citing Parks v. Ingersol-Rand Co., 380 F. App'x 190, 195-96 (3d Cir. 2010). Federal Rule of Civil Procedure 41(b) provides that “[i]f the plaintiff fails to prosecute or to comply with these rules or a court order, a defendant may move to dismiss the action or any claim against it.”
The court then noted that “the that plaintiffs failed to prosecute this case for more than thirty years,” that “in 1995 the plaintiffs failed to advise the court of the outcome of the Dickerson case,” that “the Dickerson case resulted in a settlement agreement approved by the State court that resolved the state issues,” and that the “inmates have available to them the option of initiating litigation for alleged federal constitutional violations.” Under those circumstances, the court concluded that it was appropriate to dismiss the case. Accordingly, the court denied Fatir’s motion to enforce the February 17, 1977 judgment and dismissed the case pursuant to Federal Rule of Civil Procedure 41(b).
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