Opinion · Supreme Court of the United States

Willy v. Coastal Corp.

Willy v. Coastal Corp., 503 U.S. 131 (1992)

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1992-03-03
Topic
general

How later courts describe this case

  • holding that the "expansive language" of Rule 81(c) "indicates a clear intent to have the [Federal] Rules... apply to all district court civil proceedings"
  • holding that a district court had jurisdiction to impose Rule 11 sanctions even though it was later found to lack jurisdiction over the underlying case
  • holding that a district court could constitutionally impose Rule 11 sanctions in a case in which was later determined that the court lacked subject matter jurisdiction
  • holding that the district court had the authority to impose sanctions pursuant to Fed.R.Civ.P. 11 in a case in which it later determined that it lacked subject matter jurisdiction
  • holding that a district court may impose sanctions pursuant to Rule 11 in a case in which the district court is later determined to be without subject matter jurisdiction
  • holding that a district court had jurisdiction to impose Rule 11 sanctions regardless of the existence of subject-matter jurisdiction
  • holding that district court may impose sanctions for conduct that occurred during a proceeding in which the court ultimately lacked subject matter jurisdiction
  • holding that lower courts have the power to issue Rule 11 sanctions even when they do not have subject-matter jurisdiction over the underlying controversy

Citator

UpLaw has not yet analyzed Willy v. Coastal Corp.. The absence of a flag is not a finding that it is good law.

Authority status
pending
Cited by
607 opinions

Headnotes

  1. Civil Procedure — Sanctions A federal district court may impose sanctions pursuant to Rule 11 of the Federal Rules of Civil Procedure in a case in which the district court is later determined to be without subject matter jurisdiction. 503 U.S. 131, 134-139 (1992)
  2. Civil Procedure — Scope of the Federal Rules Although the expansive language of Rules 1 and 81(c) indicates a clear intent that the Federal Rules of Civil Procedure, including Rule 11, apply to all district court civil proceedings, the Rules must be deemed to apply only if their application will not impermissibly expand the judicial authority conferred by Article III. 503 U.S. 131, 134-135 (1992)
  3. Constitutional Law — Article III — Powers of Congress Congress, acting pursuant to its authority to establish the lower federal courts and to make all laws necessary and proper thereto, may enact laws regulating the conduct of those courts and the means by which their judgments are enforced, including laws authorizing the imposition of sanctions. 503 U.S. 131, 136 (1992)
  4. Civil Procedure — Subject-Matter Jurisdiction A final determination that a federal court lacked subject matter jurisdiction precludes further adjudication of the case but does not automatically wipe out all proceedings had in the district court at a time when that court operated under the misapprehension that it had jurisdiction. 503 U.S. 131, 137 (1992)
  5. Civil Procedure — Sanctions An order imposing a Rule 11 sanction is collateral to the merits of the action, because it requires only the determination of whether the attorney has abused the judicial process and, if so, what sanction is appropriate, rather than an assessment of the legal merits of the complaint; such an order therefore implicates no constitutional concern under Article III even when the court is later found to have lacked subject matter jurisdiction. 503 U.S. 131, 137-138 (1992)
  6. Civil Procedure — Sanctions The interest in having rules of procedure obeyed does not disappear upon a subsequent determination that the court was without subject matter jurisdiction; where an immediate appeal is not authorized, there is no constitutional infirmity under Article III in requiring those practicing before the courts to comply with applicable procedural rules in the interim, and in allowing the courts to impose Rule 11 sanctions upon their failure to do so. 503 U.S. 131, 138-139 (1992)
  7. Civil Procedure — Sanctions A civil contempt order, which is designed to coerce compliance with the court's decree, falls if the court is found to have lacked subject matter jurisdiction, whereas a Rule 11 sanction, which is designed to punish a party who has already violated the court's rules, does not. 503 U.S. 131, 138-139 (1992)