La Buy v. Howes Leather Co.
1 L. Ed. 2d 290, 1957 U.S. LEXIS 1757, 352 U.S. 249 (1957)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A federal Court of Appeals has the discretionary power under the All Writs Act to issue a writ of mandamus to vacate a district court's order referring a case to a special master when the referral is a clear abuse of discretion under Rule 53(b). Calendar congestion, complexity of the issues, and the anticipated length of a trial are, by themselves, insufficient to constitute the "exceptional conditions" required for such a reference.
Facts:
- In 1950, two separate, complex antitrust lawsuits, Rohlfing and Shaffer, were initiated in federal court.
- The Rohlfing case involved 87 independent shoe repair shop operators suing six manufacturers and wholesalers for conspiracy to monopolize and fix prices in violation of federal antitrust laws.
- The Shaffer case involved six wholesalers suing six manufacturers and wholesalers on similar antitrust grounds, including price discrimination.
- Both sets of plaintiffs sought injunctive relief, treble damages, and a detailed accounting.
- After five years of extensive pre-trial proceedings, the cases were ready for trial.
- The district judge, Judge La Buy, stated that his calendar was extremely congested and that the cases were too complex and would take too long to try.
- On his own motion, Judge La Buy referred both cases in their entirety to a special master 'to take evidence and to report the same to this Court, together with his findings of fact and conclusions of law.'
- All parties to the litigation objected to the references to the master.
Procedural Posture:
- Two antitrust lawsuits were filed in the U.S. District Court for the Northern District of Illinois in 1950.
- The District Judge, petitioner La Buy, on his own motion, entered orders referring both cases to a master for trial.
- The plaintiffs in the underlying suits, the respondents here, objected and filed motions to vacate the reference orders.
- The District Judge denied the motions to vacate.
- The plaintiffs then filed petitions in the U.S. Court of Appeals for the Seventh Circuit for writs of mandamus to compel Judge La Buy to vacate his orders.
- The Court of Appeals found the references to be an abuse of discretion and issued the writs of mandamus.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal Court of Appeals have the power under the All Writs Act to issue a writ of mandamus to compel a District Judge to vacate an order referring cases to a master for trial, where the judge cited calendar congestion, complexity of the issues, and anticipated length of trial as the 'exceptional conditions' required by Rule 53(b)?
Opinions:
Majority - Mr. Justice Clark
Yes. A Court of Appeals has the power to issue a writ of mandamus to correct a district court's clear abuse of discretion in referring a case to a master, which amounts to an abdication of the judicial function. The All Writs Act grants Courts of Appeals the power to issue such writs in aid of their appellate jurisdiction. While this power should be exercised sparingly, it is appropriate in exceptional circumstances where a district court's action is so improper as to be beyond the scope of the rules it purports to follow. Rule 53(b) explicitly states that reference to a master shall be 'the exception and not the rule.' The reasons cited by the district judge—court congestion, case complexity, and expected trial length—are not exceptional conditions justifying the reference of an entire case; indeed, the complexity of antitrust litigation is a compelling reason for trial before an experienced judge, not a temporary substitute. The referral of all issues, including liability, amounted to an abdication of the judicial function, warranting supervisory intervention by the Court of Appeals.
Dissenting - Mr. Justice Brennan
No. The Court of Appeals exceeded its authority, as the district judge's order, even if erroneous, was a matter within his jurisdiction and did not thwart the appellate court's ultimate ability to review the final judgment. The majority's decision dangerously undermines the congressional policy against piecemeal, interlocutory appeals. The All Writs Act provides auxiliary power in aid of jurisdiction; it does not confer an independent appellate power to review non-final orders. A judge's error in finding an 'exceptional condition' under Rule 53(b) is a mere error of judgment, not a 'usurpation of judicial power' that mandamus is designed to correct. The litigants' inconvenience and added expense from the reference are consequences contemplated by Congress in limiting appeals to final judgments, and they do not justify the use of an extraordinary writ.
Analysis:
This case is a landmark decision on the supervisory power of federal Courts of Appeals over District Courts. It establishes that mandamus is an appropriate remedy not only for jurisdictional excess but also for a clear abuse of discretion that effectively nullifies a federal rule of procedure. By narrowly defining 'exceptional conditions' under Rule 53(b), the Court significantly curtailed the use of masters for trying entire civil cases, reinforcing the principle that litigants have a right to have their case heard by a judge. The decision signals that appellate courts can and should intervene to ensure proper judicial administration and prevent district courts from abdicating their core judicial functions, even in the face of administrative burdens like congested dockets.
