## Facts

- Two consolidated private antitrust actions under the Sherman Act were pending in the U.S. District Court for the Northern District of Illinois.
- The cases involved extensive allegations of conspiracy to monopolize and price-fixing in the shoe-repair supplies market and had generated years of preliminary motion practice.
- When the parties sought to set the matters for trial (one estimated to last about six weeks), the district judge, sua sponte, ordered both cases referred to a special master under Federal Rule of Civil Procedure 53(b).
- The orders directed the master to conduct hearings and prepare findings of fact and conclusions of law on the cases.
- The judge justified the referrals by citing an extremely congested calendar, the complexity of the cases, and the time the trials would require.
- Parties petitioned the U.S. Court of Appeals for the Seventh Circuit for writs of mandamus compelling the judge to vacate the referral orders and conduct the trials himself.

## Issues

1. Whether a court of appeals may issue a writ of mandamus under the All Writs Act, 28 U.S.C. § 1651(a), to control a district judge’s conduct in ongoing civil cases that may later come before the court on appeal.
2. Whether referring entire complex antitrust trials to a special master under Rule 53(b), based on docket congestion, complexity, and expected trial length, was an abuse of discretion warranting mandamus relief.

## Decision

- The Supreme Court affirmed the Seventh Circuit’s issuance of mandamus.
- The Court held that the court of appeals had authority under § 1651(a) to issue mandamus in aid of its potential appellate jurisdiction over the antitrust cases.
- The Court held that the district judge’s broad references to a master were an abuse of Rule 53(b) and amounted to an abdication of the judicial function.
- The Court concluded that mandamus was an appropriate remedy because post-judgment review would not adequately cure the harm from an unauthorized displacement of the district court’s trial responsibility.

## Legal Principles

- Under the All Writs Act, a court of appeals may issue mandamus “in aid of” its jurisdiction where it may later exercise appellate review, but the writ remains an extraordinary, discretionary remedy reserved for clear abuses of discretion or usurpations of judicial power.
- Rule 53(b) treats reference to a master as an exception, not a routine case-management device; masters may assist judges with specific tasks but may not displace the court in adjudicating the basic issues in litigation.
- Calendar congestion, standing alone, is not an “exceptional condition” justifying a Rule 53(b) reference of an entire case.
- Case complexity and anticipated trial length do not justify transferring core fact-finding and liability determinations to a master; such features generally strengthen the need for trial before an experienced Article III judge.
- Mandamus may issue to prevent parties from being subjected to the burden and expense of an unauthorized trial process that would be difficult to remedy effectively after final judgment.

## Conclusion

The Court upheld appellate mandamus directing a district judge to vacate sweeping Rule 53(b) referrals to a special master, holding that docket congestion, complexity, and trial length were not exceptional conditions and that delegating the core trial function to a master improperly displaced the judge’s adjudicatory role.


La Buy v. Howes Leather Co., 352 U.S. 249 (1957)