Home › Case briefs › Civil Procedure

Goodyear Tire & Rubber Co. v. Haeger

Supreme Court of the United States · 2017 · Civil Procedure

Civil ProcedureSanctionsInherent PowersAttorney's FeesDiscovery Misconductinherent powerssanctionsbad faith

Facts

The Haegers sued Goodyear after a motorhome accident allegedly caused by failure of a Goodyear G159 tire. During years of discovery, the Haegers repeatedly requested all testing data related to the G159, but Goodyear withheld internal heat-test results showing the tire became unusually hot at highway speeds. After the case settled, the Haegers learned of the undisclosed tests from another lawsuit and sought sanctions for discovery fraud. The district court found a years-long course of bad-faith misconduct and awarded all fees and costs incurred after Goodyear's first dishonest discovery response.

Issue

When a federal court uses its inherent authority to sanction a party for bad-faith litigation misconduct by ordering payment of the other side's attorney's fees, must the award be limited to fees caused by the misconduct? More specifically, is the proper standard a but-for causation test rather than an award of all fees incurred during the period of bad faith or because the conduct was especially egregious?

Rule

A federal court imposing attorney's-fee sanctions under its inherent authority through civil procedures may award only compensatory fees, not punitive ones. Therefore, the court may shift only the portion of fees the innocent party would not have incurred but for the sanctioned party's bad-faith misconduct. Trial courts may use estimates and rough justice in making that determination, and in exceptional cases may award all fees for a suit or phase of a suit if all those fees would not have been incurred absent the misconduct.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Denver, Nora Kim sued Alpine Foundry LLC for toxic exposure. The judge later found Alpine intentionally destroyed air-sampling records and, using inherent authority, ordered Alpine to pay Nora's attorney's fees plus an extra $500,000 "to punish this outrageous behavior," all imposed through ordinary motion practice without criminal-type procedures.

Which statement best describes the validity of the sanction?

Explanation. When a federal court uses inherent authority and civil procedures to shift attorney's fees, the sanction must compensate the opposing party for losses caused by the misconduct, not punish the wrongdoer. Any amount beyond fees the innocent party would not have incurred but for the bad faith is punitive and cannot be imposed absent criminal-type protections. (Derived from Goodyear Tire & Rubber Co. v. Haeger (2017).)