Link v. Wabash Railroad Company (1961)
- Docket
- 422
- Decided
- 1961-01-01
- Category
- General
Summary
Question: Can a court dismiss a case for failure to prosecute without a motion from the defendant? Conclusion: Yes. Justice John M. Harlan delivered the decision of the 4-3 majority. The Court held that a court has the right to clear its calendar of cases that have been dormant because of inaction on the part of the plaintiff without any motion from the defense. This right has long been understood as one of the inherent powers of the court and no law explicitly restricts it. The Court also held that there are circumstances where a lack of a chance for argument does not violate the right to due process. In this case, the plaintiff voluntarily chose a lawyer with potential time conflicts, and both sides had plenty of notice about the hearing. Justice Hugo L. Black wrote a dissent where he argued that the majority’s decision essentially punished the plaintiff by forcing him to accept the loss of his property without due process. He found that the court’s decision relied solely on the lawyer’s failure to appear, rather than any other want of prosecution in the history of the case. Instead, the lawyer’s attempts to contact the court and reschedule the hearing clearly indicated a desire to continue the prosecution of the case. He also argued that to punish the client for the sins of the lawyer placed an enormous and unfair burden on the client to oversee the work of his attorney. Chief Justice Earl Warren joined in the dissent. Justice William O. Douglas also dissented. Justice Felix Frankfurter and Justice Byron R. White did not participate in the discussion or decision of this case.