Sunday, November 24, 2013

Chambers v. NASCO, Inc. case brief

Chambers v. NASCO, Inc. case brief summary
501 U.S. 32 (1991)

Petitioner seller challenged a decision of the United States Court of Appeals for the Fifth Circuit, which affirmed attorney fees and expenses as a sanction for bad-faith conduct by petitioner in favor of respondent purchaser.

Petitioner was sole shareholder and director of a radio and television station. Petitioner agreed to sell the station and license to respondent. Petitioner through his attorney, changed his mind. Respondent brought suit.


  • Sanction of respondent's attorney fees and costs was affirmed where petitioner acted in bad faith in delaying and complicating issues at trial in a contract case. 
  • The court held that a district court, sitting in diversity, did not abuse its discretion when it invoked its inherent power in assessing sanction based on the circumstances. 
  • In a case for specific performance of a contract, petitioner attempted to fraud the court, continuously took action to delay proceedings, repeatedly took actions in contempt of court orders, and proceeded with a series of meritless motion and pleadings and delaying actions. 
  • The court gave repeated warnings to petitioner and his counsel that his actions were sanctionable. 
  • Statutes and Federal Rules of Civil Procedure address sanctions in no way limited court's ability to use its inherent power; they instead supplemented that power. 
  • There was no abuse of discretion in the court ordering attorney fees and expenses as a sanction.

The court affirmed the decision.

Recommended Supplements for Civil Procedure

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