Allied Chemical Corp. et al. v. Daiflon, Inc.
449 U.S. 33 (1980)
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Rule of Law:
A writ of mandamus is an extraordinary remedy that cannot be used to obtain interlocutory review of a trial court's discretionary order granting a new trial, as such an order is reviewable on direct appeal after a final judgment is entered.
Facts:
- Daiflon, Inc., a small importer of refrigerant gas, brought an antitrust suit against domestic manufacturers of the gas.
- E. I. du Pont de Nemours & Co. was one of the manufacturers sued.
- Daiflon alleged that Du Pont monopolized the refrigerant gas industry in violation of the Sherman Act.
- Daiflon also alleged that all the petitioner manufacturers conspired to drive Daiflon out of business.
Procedural Posture:
- Daiflon, Inc. sued E. I. du Pont de Nemours & Co. and other manufacturers in federal district court (the trial court).
- Following a trial, the jury returned a verdict in favor of Daiflon for $2.5 million.
- Petitioners filed a motion for judgment notwithstanding the verdict and a motion for a new trial.
- The trial court denied the motion for judgment notwithstanding the verdict but granted the motion for a new trial.
- Daiflon then filed a petition for a writ of mandamus with the Court of Appeals for the Tenth Circuit (the intermediate appellate court), asking it to compel the trial court to reinstate the jury verdict.
- The Court of Appeals issued the writ of mandamus, restoring the verdict on liability but permitting a new trial on damages.
- Petitioners (Du Pont et al.) sought a writ of certiorari from the U.S. Supreme Court (the highest court) to review the appellate court's decision.
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Issue:
Does a federal court of appeals have the authority to issue a writ of mandamus to overturn a district court's discretionary order granting a new trial?
Opinions:
Majority - Per Curiam
No. A court of appeals cannot issue a writ of mandamus to overturn a trial court’s discretionary order granting a new trial because the writ is an extraordinary remedy reserved for circumstances where there is no other adequate means of review, and such an order can be reviewed on direct appeal after a final judgment. The remedy of mandamus is a drastic one, to be invoked only in extraordinary situations amounting to a judicial usurpation of power, not to correct simple errors. To obtain the writ, a party must show they have no other adequate means to attain relief and their right to the writ is 'clear and indisputable.' An order for a new trial is interlocutory and can be reviewed after a final judgment, so an adequate alternative remedy exists. Furthermore, the decision to grant a new trial is committed to the trial court's discretion, meaning a party's right to a contrary result is not 'clear and indisputable.' Allowing mandamus in this context would undermine the congressional policy against piecemeal appellate review.
Dissenting - Justice Blackmun
The Court should not have summarily reversed the Court of Appeals. While agreeing with the general principles regarding the extraordinary nature of mandamus, the dissent argues that the case appears unusual and may involve exceptional circumstances justifying the writ's issuance. The dissent would have granted certiorari and given the case plenary consideration to carefully examine the factors that prompted the Court of Appeals to act, rather than deciding the matter peremptorily. If the record before the appellate court was inadequate, the proper remedy would be to remand for further proceedings, not to reverse.
Analysis:
This decision strongly reaffirms the final judgment rule and the extremely limited availability of the writ of mandamus as a tool for interlocutory appeal. It clarifies that discretionary orders by a trial judge, even if potentially erroneous, are not the type of 'judicial usurpation of power' that justifies the extraordinary remedy of mandamus. The ruling protects the trial court's discretion, particularly in granting new trials, and prevents the litigation process from being derailed by piecemeal appeals. By strictly enforcing the final judgment rule, the Court promotes judicial efficiency and reinforces the established appellate structure.
