## Facts

- Plaintiffs filed a federal antitrust action against the National Hockey League and related defendants.
- The district court ordered plaintiffs to answer written interrogatories as part of discovery.
- Over approximately 17 months, plaintiffs repeatedly failed to provide required interrogatory responses despite multiple extensions, court admonitions, and assurances that responses would be provided.
- The district court found plaintiffs’ discovery conduct reflected “flagrant bad faith” and a “callous disregard” of counsel’s responsibilities to the court and opposing parties.
- As a sanction under Federal Rule of Civil Procedure 37(b)(2)(C), the district court dismissed the complaint.
- The Third Circuit reversed, concluding dismissal was an abuse of discretion.
- The Supreme Court granted certiorari to review whether the district court abused its discretion in imposing dismissal.

## Issues

1. Whether the district court abused its discretion under Federal Rule of Civil Procedure 37(b)(2)(C) by dismissing the action for failure to obey discovery orders.
2. Whether plaintiffs’ noncompliance reflected inability to comply, or instead willfulness, bad faith, or fault sufficient to justify dismissal.

## Decision

- The Supreme Court reversed the Third Circuit.
- The Court held the district court did not abuse its discretion by dismissing the complaint as a Rule 37 sanction.
- The Court relied on the district court’s findings that plaintiffs’ prolonged noncompliance, despite warnings and extensions, demonstrated “flagrant bad faith” and “callous disregard.”
- The Court treated dismissal as permissible where noncompliance is attributable to willfulness or bad faith rather than inability to comply.

## Legal Principles

- Rule 37(b)(2)(C) authorizes dismissal of an action as a sanction for disobeying discovery orders.
- Dismissal is an extreme sanction, but it may be imposed when a party’s failure to comply is willful, in bad faith, or otherwise attributable to the party’s fault, rather than to inability to comply.
- Appellate review of Rule 37 sanctions is for abuse of discretion, and substantial deference is owed to a trial court’s management of discovery and assessment of misconduct.
- Counsel’s misconduct in discovery may support terminating sanctions when it reflects bad faith and disregard of court-ordered obligations.

## Conclusion

The Court upheld dismissal under Rule 37 where a lengthy pattern of ignored discovery obligations, despite repeated extensions and admonitions, supported findings of willful, bad-faith noncompliance, and it reaffirmed deferential abuse-of-discretion review of trial court sanctions decisions.


National Hockey League v. Metropolitan Hockey Club, Inc., 427 U.S. 639 (1976)