In re New Motor Vehicles Canadian Export Antitrust Litigation
2005 U.S. Dist. LEXIS 14109, 229 F.R.D. 35, 2005 WL 1646030 (2005)
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Rule of Law:
Under Federal Rule of Civil Procedure 16, a trial court has broad authority to manage complex litigation through a scheduling order, which includes controlling the timing of summary judgment motions. A party may not unilaterally file a dispositive motion that deviates from an established litigation schedule without first seeking leave from the court and showing good cause.
Facts:
- Plaintiffs alleged that multiple car manufacturers, including General Motors, along with car dealers and trade associations, engaged in a conspiracy.
- The purpose of the alleged conspiracy was to improperly restrict the import and sale of new Canadian motor vehicles in the United States market.
- Plaintiffs claimed this alleged restriction resulted in them paying artificially inflated prices for new vehicles in the U.S.
- The plaintiffs asserted claims against the defendants under federal and state antitrust laws, state consumer protection laws, and for unjust enrichment.
Procedural Posture:
- The Judicial Panel on Multidistrict Litigation transferred 26 related antitrust cases to the U.S. District Court for the District of Maine for consolidated pretrial proceedings.
- Plaintiffs filed a Consolidated Amended Complaint, which was subsequently amended multiple times.
- Defendants filed several complex motions to dismiss, on which the court issued detailed rulings.
- The court, with input from the parties, entered a Scheduling Order governing discovery and proceedings related to class certification, with deadlines extending through December 2005.
- While class certification discovery was ongoing, defendant General Motors unexpectedly filed a motion for summary judgment.
- In response, the plaintiffs filed a Motion to Stay their obligation to respond to General Motors' summary judgment motion, which is the subject of this order.
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Issue:
Does a party in a complex multidistrict litigation have an absolute right under Federal Rule of Civil Procedure 56 to file a summary judgment motion at any time, even when doing so would disrupt a court-approved scheduling order established under Federal Rule of Civil Procedure 16?
Opinions:
Majority - Hornby, District Judge
No. A party in a complex multidistrict litigation does not have an absolute right to file a summary judgment motion at a time that disrupts a court-managed schedule. A court's authority under Federal Rule of Civil Procedure (FRCP) 16 to manage litigation and set schedules, including the timing of motions, limits a party's ability to file for summary judgment 'at any time' under FRCP 56. In this complex multidistrict case, the court and the parties had established a detailed scheduling order focused on class certification discovery and briefing. General Motors' surprise summary judgment motion was not contemplated by this schedule and was filed without seeking permission to modify it. Allowing this 'stealth motion' would disrupt the orderly progression of the litigation, undermine the court’s case management authority, and be unfair to other parties who were adhering to the schedule.
Analysis:
This order strongly affirms the discretionary power of trial judges to manage complex litigation under FRCP 16. It clarifies that the permissive language of FRCP 56, which allows a summary judgment motion 'at any time,' is not absolute and is subordinate to a court's specific scheduling order. The decision serves as a significant precedent for practitioners in multidistrict litigation (MDL) and other complex cases, emphasizing that judicial case management plans are binding and that tactical filings which disrupt them will not be tolerated. The ruling reinforces the principles of candor and cooperation expected from counsel and solidifies the court's role in preventing 'wasteful pretrial activities' and ensuring cases proceed efficiently.
