Monday, October 28, 2013

In re Trinity Industries, Inc. case brief

In re Trinity Industries, Inc. case brief summary
876 F.2d 1485 (1989)

CASE SYNOPSIS
In these consolidated appeals, appellant companies challenged the orders from the United States District Courts for the Northern District of Alabama and the Middle District of Florida, which found appellants in contempt of court for failure to honor Occupational Safety and Health Administration inspection warrants.

CASE FACTS
Appellants, an Alabama company and a Florida company, were held in contempt of court for failure to honor Occupational Safety and Health Administration (OSHA) inspection warrants.

DISCUSSION
  • On appeal, the court found that the warrant applications provided sufficient information to enable the magistrate to conclude that appellants were selected by specific, neutral criteria, and thus met the test under Marshall v. Barlow's, Inc. for probable cause. 
  • With respect to sanctions imposed against Florida appellant, Florida appellant's actions made obvious the need for the lower court to resort to coercive tactics to secure compliance with its contempt orders. 
  • With respect to attorney fees, the lower court properly limited appellee's recovery to amounts expended in the post-Alabama litigation phase, since appellee's efforts during that phase were those which directly led to the ultimate finding of contempt. 
  • However, the court remanded the issue of attorney fees with regard to Alabama appellant, because there was no explanation of the basis of the denial of appellee's request for the fees.

OUTCOME

The orders holding appellant companies in contempt of court were affirmed in part, because there was no abuse of discretion in issuing the warrants, imposing sanctions on Florida appellant, or awarding appellee Secretary of Labor attorney fees from Florida appellant; however, the award of attorney fees as to the Alabama appellant was reversed, because there was no explanation of the basis for denying appellee's request for said fees.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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